HomeMy WebLinkAbout01-03763
.,.
~.
~J
"
GOLDBECK McCAFFERTY
BY: Joseph A. Goldbeck,
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
& McKEEVER
Jr.
GE CAPITAL MORTGAGE SERVS. INC.
4680 Hallmark Parkway
San Bernardino, CA 92407
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
vs.
:ACTION OF MORTGAGE FORECLOSURE
OLLIE B. MARTIN III AND
TAMILLA A. MARTIN
(Mortgagor(s) and Real Owner(s))
6 Koser Road
Shippensburg,
PA 17257
Defendant(s)
Term l'-r-
No. 01 -.31'-3 Gu~ . 1€IL~
CIVIL ACTION: MORTGAGE
FORECLOSURE
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.
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 claimed in the Complaint
or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUmPerland County Bar Association
2 L~berty Avenue, Carlisle, PA
(800) 990-9108
Leg~l Services Inc.
8 I~vine Row, Carlisle, PA 17013
(711) 243-9400
AVISO
LE RAN DEMANDADO A USTED EN LA CORTE. S1 DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES
ABSOLUTAMEN'I'E NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DrAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO.
PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PONTO DE VISTA
DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECVERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION.
ENTONCES, LA COUTE PUEDE, SIN NOTIFlCARIO, 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 OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS),
215-238-6300.
CuffiPerland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
Leg~l Services Inc.
8 I~vine Row, Carlisle, PA 17013
(711) 243-9400
.
r
COMPLAINT IN MORTGAGE FORECLOSURE
<',
..1
1. plaintiff is GE CAPITAL MORTGAGE SERVS. INC., 4680
Hallmark Parkway, San Bernardino, CA 92407.
2. The name(s) and address(es) of the Defendant(s) is/are
OLLIE B. MARTIN III, 1870 Aeronca, Carlisle, PA 17013 and TAMILLA
A. MARTIN, 1870 Aeronca, Carlisle, PA 17013, who is/are the
mortgagor(s) and real owner(s) of the mortgaged property
hereinafter described.
3. On August 26, 1998, mortgagor(s) made, executed and
delivered a mortgage upon the premises hereinafter described to GE
CAPITAL MORTGAGE SERVS. INC., which mortgage is recorded in the
Office of the Recorder of Deeds of Cumberland County in Mortgage
Book 1482, Page 223. The mortgage has not been assigned. These
documents are matters of public record and are incorporated herein
by reference in accordance with Pennsylvania Rule of Civil
Procedure 1019(g).
4. The premises subject to said mortgage is described as
attached.
5. The mortgage is in default because monthly payments of
principal and interest upon said mortgage due September 1, 2000,
and each month thereafter are due and unpaid, and by the terms of
said mortgage, upon default in such payments for a period of one
month, the entire principal balance and all interest due thereon
are collectible forthwith.
6. The following amounts are due on the mortgage:
Principal Balance
Interest from 8/ 1/00
through 6/30/01 at 7.250%
Per diem interest rate at $12.40
Attorney's Fee at 5%
of Principal Balance
Late Charges 9/ 1/00- 6/30/01
Monthly late charge amount at $17.36
Costs of suit and Title Search
Escrow Balance Deficit
Monthly Escrow amount $115.46
$ 62,393.89
4,129.20
3,119.69
173.60
560.00
$ 70,376.38
475.06
$ 70,851.44
7. The Attorney's Fees set forth above are in conformity
wi th the Mortgage documents and Pennsylvania law, and, will be
collected in the event of a third party purchaser at Sheriff's
Sale. If the Mortgage is reinstated prior to the Sale reasonable
Attorney's Fees will be charged based on work actually performed.
"
- - ,
"
~., :.ij--."
8. 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
the sum of $70,851.44, together with interest at the rate of
$12.40, per day and other expenses incurred by the Plaintiff which
are properly chargeable in accordance with the terms of the
mortgage, and for the foreclosure and sale of the mortgaged
premises.
By:
GO
BY:
Att
R
Esq.
,-"
"",.<:, t "
, ~-. _ -cr ."
".-17
~,
.
"
VERIFICATION
I,
, as the representative of the
Plaintiff corporation within named do hereby verify that I am
authorized to and do make this verification on behalf of the
Plaintiff corporation and the facts set forth in the foregoing
Complaint are true and correct to the best of my knowledge,
information and belief, I understand that false statements therein
are made subject to the penalties of 18 Pa, C.B, 4904 relating to
unsworn falsification to authorities,
Date: {; /; 510/
1:&udI dij/~
.~,-" , . ~, .,_;1:
LEGAL DESCRIPTION
ALL THAT CERTAIN piece or parcel of land situale in North Newton
Township, Cumberland County, Pennsylvania, more particularly bounded and described as
follows, to wit:
BEGINNING at a railroad spike in Ihe center line of Township Roule 330 at
corner of lands now or formerly of Dana L. Peterson etux; thence by said lands of Pelerson,
South 42 degrees 05 minutes 30 seconds,West, 231.32 (eetlo an iron pin in the properly line
of lands now or formerly of W. Harold Yohe; thence by said lands of Yohe, North 68 degrees
27 minutes 06 seconds West, 130.24 feet 10 an existing comer fence post; thence hy same,
North 41 degrees 15 minutes 26 seconds East, 199.35 feet 10 an iron pin; thence continuing hy
same, North 6S degrees 26 minuteS 00 seconds Wesl.' 26.19 feet to all iron pin at comer of lands
now or formerly of Norman 1. West; thence by said lands of Wesl, Norlh 42 degrees 05 minutes
30 seconds .East, 92.55 feet to a railroad spike in the eeiller line of said Township Roule 330;
thence by said center line of said Township: Roule. South 45 degrees 14 minules 37 seconds
East, 150 feet to a railroad spike, lhe place qf BEGINNING. .
BEING Lot No.2 on land subdivision for Dana L. Peterson, daled March 12,
1982 and recorded in the Office of Recorder of Deeds of Cumberland County. Pennsylvania in
Plan Balik 42, Page 17. Containing 34,075 square feel. less 3,750 square feet reserved for
right-of-way use.
BEING the same premises conveyed by Paul A. Askey Jr. and Sharon I.
Askey, husband and wife, by their deed dated January 27, 1995, and
recorded in Cumberland County~Deed Book 118, Page 68, unto Ollie B.
Martin III and Tamilla A. Martin, husband and wife, the Mortgagors
herein.
,. . ... ..'~ ~ '
....'-'" .S.....~-"'.."
" ....'ft' ~'f) f:;:- .',
.... ()~'.'..:,;:_~,. '^/C't~i
State 01 pennsylvania} 86 ,i O~"-;C:'P~~1i!)..~.'^'1)"
Count'! of Cumberland: ~.. t.;.....c '::0 ~. b'''....j;., '.
Re~ed i the office for the recording of Deeds ~ '~.'. ,,! ~.:'.'..\-.;'.:,;> !:;.'~.,I/. At.'}.6-"~
ect \ nd f erland County, ~ b'.: ~';, " . .;--_.;:..; ~rI~>. :~,t? .
. --"" P st ~ 'I)t. '.,''' ,^.',~.; ,.~ r . <t .
'In Bno )1._ a ':1 ,--..,;;,t'\:t~''''~-?'~'A '.'#.-,', '
~ . v. .'.-.'0,' p. 'Of' .fV . . '
wiln 55 my nand al of off ' . ~~ ~,~\ ~"~~~;..E:" .:': '. /
Carlise,PAtb' dayo.' 19_ \:~~.~,,::-:~~.~;:,"::(?l/
'It'l<- .,;': 0......... f'..... ~~~.
.,,~;;; ~"'R." "'1i'\\"-~.
~a,;r. ,I;; ',~''''''<,..1 ~"':.~':':"-
~'~'. .....". ~ '_~~'~'"..MP. _.....,... ~~
,~""',_..,........-J:." "
"'."il'.....~ .,..,,- .,.,~'
'1lfI!'~q~~,;-;,~;lf' :,.
Bood482 PAGE '231:
~MlijJ<iIlli_ll!IIDlliilikailllidli'j~1bi-'iiMi"iil'~~!O:BJ,H""!~\lli!V"~,,,4"'-:,',,(JiI"" _"'",1.k,,j,,,,,,,,&~1I\1llI~1
,"-~-
fl \ ~ 1Q..
~ (') c:> 0 e
~ c:
~;;<r "-1
~ -o~...", C._
...... 8 (> n,L'::--' s:;
~G:
......... ~ ~s;~ ..a-
~
~ I . _..---::;-" ,):;)
i;::; ~i~j
~ j> -, ~ -,:T1
p: z( ,
'-t s;: (:5 ;-~-~ ( ~,
C..: r- ~~':I J"T!
:2: .. ~
~ :< :::>
(7'1 :D
-<
\...!..,
" ,,~,~~ -~
~
O~~ ~ "~
-
"
"
.-1
~- ~ , ~f
~"I
SHERIFF'S RETURN - REGULAR
.CAS, NO: 2001-03763 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GE CAPITAL MORTGAGE SERVS INC
VS
MARTIN OLLIE BIll ET AL
DEP SHANNON SUNDAY
, Sheriff or Deputy Sheriff of
Cumberland County,pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
MARTIN OLLIE BIll
the
DEFENDANT
, at 1050:00 HOURS, on the 17th day of July
, 2001
at 30 OAK HILL ROAD
CARLISLE, PA 17013
by handing to
OLLIE B MARTIN III
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
3.90
.00
10.00
.00
31.90
r~~~t;~
R. Thomas Kline
Sworn and Subscribed to before
07/18/2001
GOLDBECK,MCCAFFERTY & MCKEEVER
By:SL fYt.~~.
Deputy Sheriff
me this ~J,ut day of
0~ ~ A.D.
t<..- . )u,,,b,) A~
P othonotary ,
,
-
.,
. '.....l " __~ _ 1.>' ,
~I
SHERIFF'S RETURN - REGULAR
.CAS1\. NO: 2001-03763 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GE CAPITAL MORTGAGE SERVS INC
VS
MARTIN OLLIE BIll ET AL
DEP SHANNON SUNDAY
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
MARTIN TAMILLA A
the
DEFENDANT
, at 1651:00 HOURS, on the 17th day of July
, 2001
at 758 SHIPPENSBURG ROAD
NEWVILLE, PA 17241
by handing to
TAMILLA MARTIN
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
6.00
.00
10.40
10.00
.00
26.40
r"~H~~f!
R. Thomas Kline
Sworn and Subscribed to before
07/18/2001
GOLDBECK,MCCAFFERTY & MCKEEVER
By: SiCUrvMrrL frI. SUJt~
Deputy Sheriff
me this 26M'- day of
q~r ~/ A.D.
C rI::1u () lMJp'AJ ~
honotary I
J
, ""_ . "- - I - . ~,-,.>~"-' _"j-_
,
GOLDBECK McCAFFERTY & McKEEVER
By: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
(2] 'i) b/.7-11/./.
ATTORNEY FOR PLAINTIFF
GE Capital Mortgage Services, Inc.
4680 Hallmark Parkway
San Bernardino, CA 92407
Vs.
Ollie B. Martin III
758 Shippensburg Road
Newville, PA 17241
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO 01-3763-Civil Term
Tamilla A. Martin
30 Oak Hill Road
Carlisle, PA 17013
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF D~GES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against
Ollie B. Martin It I and Tamilla A. Martin, Defendants for failure to file
an Answer to Plaintiff's Complaint within 20 days (or 60 days if defendant
is the United States of America) from the date of service of the complain
and for foreclosure and sale of the mortgaged premises, and assess
Plaintiff's damages as follows:
As set forth in Complaint
Interest - 7/1/01 _ 9/11/01
Late Charges
Escrow Debit
TOTAL
$70,851.44
$ 905.20
$ 52.08
S 346.38
$72,155.10
I hereby certify that (1) the addresses of the Plaintiff and
Defendants are as shown above, and (2) that notice has been given in
accordance with Rule 237.1, copy attached.
DATE:
mm["!" . ?~
.,;d;;; ~ .
PRO PROTHY
DAMAGES ARE HEREBY ASSESSED AS
I hereby certify that the above names are correct and that the
precise residence address of the judgment creditor is 4680 Hallmark
Parkway, San Bernardino, CA 92407 and that the names and last known
addresses of the Defendants are:
Ollie B. Martin Ill, 758 Shippensburg Road, Newville, PA 17241
Tamilla A. Martin, 30 Oak Hill Road, Carlisle, PA 17013
dbeck, Jr.
Plaintiff
~ ~" ,",-. .-, ,
,~
TO: OLLIE B. MARTIN III
6 Koser Road
Shipp ens burg , PA 17257
GE CAPITAL MORTGAGE SERVS. INC.
4680 Hallmark Parkway
San Bernardino, CA 92407
Plaintiff
vs.
OLLIE B. MARTIN III AND TAMILLA A.
MARTIN (Mortgagor(s))
(Record Owner(s))
6 Koser Road
Shippensburg, PA 17257
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 01-3763 (Civil Term)
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.
TO: OLLIE B. MARTIN III
6 Koser Road
Shippensburg, PA 17257
DATE OF THIS NOTICE: August 7, 2001
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:
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
/s/ JO:lpph .A. goldbeck. Jr.
GOLDBECK McCAFFERTY r. McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 500 - The Bourse Bldg.
III S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
-, -'- ">wI
ero: TAMILLA A. MARTIN
6 Koser Road
Shippensburg, PA 17257
GE CAPITAL MORTGAGE SERVS. INC.
4680 Hallmark Parkway
San Bernardino, CA 92407
Plaintiff
vs.
OLLIE B. MARTIN III AND TAMILLA A.
MARTIN (Mortgagor(sll
(Record Owner(sl)
6 Koser Road
Shippensburg, PA 17257
Defendant (s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 01-3763 (Civil Term)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFO~TION OBTAINED FROM YOU WILL BE USED
FOR THE PURPOSE OF COLLECTING THE DEBT.
TO: TAMILLA A. MARTIN
6 Koser Road
Shippensburg, PA 17257
DATE OF THIS NOTICE: August 7, 2001
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:
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
/s/ JOdeph --4. goldbeck. Jr.
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
. .
"' ,^ ,
,. .~ ',~ " '
,-'.^
,I
TO: TAMILLA A. MARTIN
1870 Aeronica
Carlisle, PA 17013
GE CAPITAL MORTGAGE SERVS. INC.
4680 Hallmark Parkway
San Bernardino, CA 92407
Plaintiff
vs.
OLLIE B. MARTIN III AND TAMILLA A.
MARTIN (Mortgagor(s))
(Record Owner(s))
6 Koser Road
shippensburg, PA 17257
Defendant(sl
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 01-3763 (Civil Term)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFO~TION OBTAINED FROM YOU WILL BE USED
FOR THE PURPOSE OF COLLECTING THE DEBT.
TO: TAMILLA A. MARTIN
1870 Aeronica
Carlisle, PA 17013
DATE OF THIS NOTICE: August 7, 2001
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:
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
Isl JOdeph --4. goldbeck. Jr,
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
- ",1
TO: OLLIE B. MARTIN III
1870 Aeronica
Carlisle, PA 17013
GE CAPITAL MORTGAGE SERVS. INC.
4680 Hallmark Parkway
San Bernardino, CA 92407
Plaintiff
vs.
OLLIE B. MARTIN III AND TAMILLA A.
MARTIN (Mortgagor(s))
(Record Owner(s))
6 Koser Road
Shippensburg, PA 17257
Defendant (s)
IN CI:HE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 01-3763 (Civil Term)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFO~TION OBTAINED FROM YOU WILL BE USED
FOR THE PURPOSE OF COLLECTING THE DEBT.
TO: OLLIE B. MARTIN III
1870 Aeronica
Carlisle, PA 17013
DATE OF THIS NOTICE: August 7, 2001
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:
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
Isl JOdeph --4, goldbeck. Jr,
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
~"" - ,.
....d
TO: OLLIE B. MARTIN III
758 Shippensburg Road
Newville, PA 17241
GE CAPITAL MORTGAGE SERVS. INC.
4680 Hallmark Parkway
San Bernardino, CA 92407
Plaintiff
vs.
OLLIE B. MARTIN III AND TAMILLA A.
MARTIN (Mortgagor(s))
(Record owner(s))
6 Koser Road
Shippensburg, PA 17257
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 01-3763 (Civil Term)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFO~TION OBTAINED FROM YOU WILL BE USED
FOR THE PURPOSE OF COLLECTING THE DEBT.
TO: OLLIE B. MARTIN III
758 Shippensburg Road
Newville, PA 17241
DATE OF THIS NOTICE: August 7, 2001
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:
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
Isl JOd~Dh --4. goldbeck. Jr.
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
~~.
,-, ,.-. '^.
- -.~
J
TO: TAMILLA A. MARTIN
758 Shippensburg Road
Newville, PA 17241
GE CAPITAL MORTGAGE SERVS. INC.
4680 Hallmark Parkway
San Bernardinol CA 92407
Plaintiff
vs.
OLLIE B. MARTIN III AND TAMILLA A.
MARTIN (Mortgagor(s))
(Record Owner(s))
6 Koser Road
Shippensburg, PA 17257
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 01-3763 (Civil Term)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFO~TION OBTAINED FROM YOU WILL BE USED
FOR THE PURPOSE OF COLLECTING THE DEBT.
TO: TAMILLA A. MARTIN
758 Shippensburg Road
Newville, PA 17241
DATE OF THIS NOTICE: August 7, 2001
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:
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
Isl JOdeph --4. goldbeck, Jr,
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
"~. '
00"'"
_ - -J
TO: TAMILLA A. MARTIN
30 Oak Hill Road
Carlisle, PA 17013
GE CAPITAL MORTGAGE SERVS. INC.
4680 Hallmark Parkway
San Bernardino, CA 92407
Plaintiff
vs.
OLLIE B. MARTIN III AND TAMILLA A.
MARTIN (Mortgagor(s))
(Record Owner(s))
6 Koser Road
Shippensburg, PA 17257
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 01-3763 (Civil Term)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY lNFO~TION OBTAINED FROM YOU WILL BE USED
FOR THE PURPOSE OF COLLECTING THE DEBT.
TO: TAMILLA A. MARTIN
30 Oak Hill Road
Carlisle, PA 17013
DATE OF THIS NOTICE: August 7, 2001
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:
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
Isl JOdeph --4. goldbeck. Jr,
GOLDBECK McCAFFERTY &,McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
.,,"
- ,"-, "" ',- ~'. ~
"",_,;1
TO: OLLIE B. MARTIN III
30 Oak Hill Road
Carlisle, PA 17013
GE CAPITAL MORTGAGE SERVS. INC.
4680 Hallmark Parkway
San Bernardino, CA 92407
Plaintiff
vs.
OLLIE B. MARTIN III AND TAMILLA A.
MARTIN (Mortgagor(s))
(Record owner(s))
6 Koser Road
Shippensburg, PA 17257
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 01-3763 (Civil Term)
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.-
TO: OLLIE B. MARTIN III
30 Oak Hill Road
Carlisle, PA 17013
DATE OF THIS NOTICE: August 7, 2001
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:
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
Isl JOdeph --4, goldbeck, Jr.
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
"
,
.. _, i. .......,~~.,
t 7Y ~ ~ 0 c:'
c <-)
t:l :-D :?" "
-0'.' (/)
& rnFfi ,.TJ
z:u v
- zr....o:.
r ..... (f)~> co
...... -<'"
...... ~~ r:;(:.':" '__I
<::""' '-'
r .,:;: -n
zC) :i: --:"'-"1
~, \"'" "'-=-C) :::;. (;
~ -~'C G.J (jrn
~~ ~ U1 .:..;:_-1
,..J->
~ (0 .-,.,
R: -<
~~,,~, .
"..",
" "
.'-,-,,'
:.I.,
GOLDBECK, MCCAFFERTY & MCKEEVER
By: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 500-The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
{?l'i\ 6?7-1::\2?
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
GE Capital Mortgage Services, Inc.
Vs.
No. 01-3763-civil
Term
Ollie B. Martin III
Tamilla A. Martin
CUMBERLAND COUNTY
VERIFICATION OF NON-MILITARY SERVICE
JOSEPH A. GOLDBECK, JR., ESQUIRE, hereby verifies that
he is attorney for the plaintiff in the above-captioned matter,
and that on information and belief, he has knowledge of the
following facts, to wit:
(a) that the defendants are not in the Military or
Naval Service of the United States or its Allies, or otherwise
within the provisions of the Soldiers' and Sailors' Civil Relief
Act of Congress of 1940, as amended.
(b) that defendant Ollie B. Martin III, is over 18 years of
age, and resides at 758 Shippensburg Road, Newville, PA 17241.
(c) that defendant Tamil1a A. Martin, is over 18 years
of age, and resides at 30 Oak Hill Road, Carlisle, PA 17013.
This statement is made subject to the penalties of 18
Pa. C.S. Section 4904 relating to unsworn falsification to
authorities.
September 11, 2001
OLDBECK, JR.
or Plaintiff
-
~~~~~-~i:i!I'"~~;1$i.1ii!'WE!!!om~~IDJ~lIl';:~ril~il\;,;t"~:1!",,-n-";'_"-'
_f.'_"'"",..,,,., '_'M. ,_~,
"L'''n,,;;:,r,d~.u,~.DiLlliitl._ H~""d~~,,~!;;;;;'-fi!I~~ilItf~"-'-'
n~" '
iillill
\:
I:;
"
"
hl
(") CO :;:)
C 1
;<.":""" (/)
-0 c", t"" "
n1ri'I -0 -,-
Z:TJ ---
ZC <::f) '-
~:~~ ::~:;(;)
~G -U , I',
..',:,-r\
~C} ~...,.':r ,,'0
""'0 S:? ~~rn
;J>C
"7 :J1
::;! :JJ
<10 -c
-
.
_ l \,,~, ~." ""
wi
(Rule of civil Procedure No. 236) - Revised
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
GE Capital Mortgage Services, Inc.
, Plaintiff
Vs.
NO. 01-3763-Civil Term
Ollie B. Martin III
Tamilla A. Martin
, Defendants
Notice is given that a Judgment in the above captioned
matter has been entered against you on September ~ 2001.
~ ~a". , ~JIA'J:.('5EPUTY
If you have any
ing this matter please
contact:
dbeck, Jr.
Plaintiff
UTHIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND
ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU
HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT
AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,
BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. U
b"
..
'i
, ;, "'~'
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P. 3180-3183
GE Capital Mortgage
Services, Inc.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
Plaintiff
NO: 01-3763-Civi1 Term
Vs.
Ollie B, Martin III
Tamilla A. Martin
PRAECIPE FOR WRIT OF EXECUTION
(MORTGAGE FORECLOSURE)
Defendants
TO THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due
Interest from 9/11/01 to sale date
at $11.86 per diem
Total
$72,155.10
$
$
and Costs
ph A. G ldbeck, Jr.
e 50 - he Bourse Bldg.
1 S. Independence Mall East
Philadelphia, PA 19106
Attorney for Plaintiff
Note: Please attach description of property.
t;~~~h'4:MJ6t~liE;'fljt&'&;~oi\~"';;Chgf''!~'Bf'-t';':I<,<",w;;'''''''i'''i-'''''.l,,,,,
"";,J.""A,iJ,j""''''''M"II,'Ill@illi'1~_j\BIIilJ.l!:~-,B1>,1,w...'il<..,;;;g_.;iliW;''~"
iill.mJ
UI -
,.,~~"""
.
1Zi<ll 0
OH I'l
~~ H ~
'0
Ei , H III
III E:~ 0
...:1...:1 Q) ~..-I 'D
dl l3t~ ..,
Eo' 0 H U Q) '" ..-I Q)
:z;~ "M H I'l IZ1 I-< tnN '00 ~
....1 > H "M ~ ;:I I-<r-- Illr--
-~I ~fil I-< ..., IZ1 III ;:1..-1 0..-1 Q)
>. Q) I'l I-< 0 .Q Il:: rJl
'~I Ul 'M III 1Zi..-l III <ll ..-i~
(.;, o ' ...,=:: o 0 1'll3t Q)
I U:>< Q) I-< Q) Q) ..-i ..Q
<,", ~~ tn III . E-< I-< P, , 'M ,
". III III =:: <ll H 0 p'Q) II: Q) ~
['-. tn l> ~1Zi 'M ..-i ..-i
<,", E-<O ..., . III ,rl..-i ..I<: III 8
, ~U I-< lQ..-i Il:: Q) tIl'M III "M
rl ~ ..-i o tn ~ O..-i rJl
C' 8~ Q) 'M IZi ~ I-< H
;::: m o III Q)
..-i ..., :z; ..,U '"
C' III ..-iE-< IZ1 I-< m
iZi IZ1Il:: ..., 0 l3t 0 '"
II:IZ1 'M H=::
~~ ~ U~ Q)
IZ1 'D H
U ~ Q) Q)
HU ,.., .r::
IZ1 l3t ..-j :;:
Cl Ii<
,In!,l!I.._~",,,_
~.,,~ ~, -" " " -
~~-
.
'-'QII~.
'"
."'-
,
, ~'" ,. '," ~ ~-
". ~;;. .
, .",1
..'4l '. "'...
.
GOLDBECK McCAFFERTY & McKEEVER
By: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
(215) 627-1322
ATTORNEY FOR PLAINTIFF
GE Capital Mortgage Services, Inc.
4680 Hallmark Parkway
San Bernardino, CA 92407
Vs.
Ollie B. Martin III
758 Shippensburg Road
Newville, PA 17241
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO 01-3763-Civil Term
Tamil1a A. Martin
30 Oak Hill Road
Carlisle, PA 17013
ALL THAT CERTAIN piece or parcel of land situate in North Newton
Township, Cumberland County, Pennsylvania, more particularly
bonded and described as follows, to wit:
BEGINNING at a railroad spike in the center line of Township
Route 330 at corner of lands now or formerly of Dana L. Peterson
et ux; thence by said lands of Peterson, South 42 degrees 05
minutes 30 seconds West, 23l.32 feet to an iron pin in the
property of lands now or formerly of W. Harold Yohe; thence by
said lands of Yohe, North 68 degrees 27 minutes 06 seconds West,
130.24 feet to an existing corner fence post; thence by same,
North 41 degrees 15 minutes 26 seconds East, 199.35 feet to an
iron pin; thence continuing by same, North 65 degrees 26 minutes
00 seconds West, 26.19 feet to an iron pin at corner of lands
now or formerly of Norman I. West; thence by said lands of West,
North 42 degrees 05 minutes 30 seconds East, 92.55 feet to a
railroad spike in the center line of said Township Route, South
45 degrees 14 minutes 37 seconds East, 150 feet to a railroad
spike, the place of BEGINNING.
Tax Parcel #30-11-0306-007A
Being known as 6 Koser Road, Shippensburg, PA 17257
~~Jwl~!tMli~*"',~'''il',1t-:ti~''''''lJtW!Mi'!-~~''N''--,1:.""",~"" ""-""'-'"F";"~"",:",,,,'i;;,~,,nd~~i!lJfl;'" ~,
-~~"'Ji~_'!i<.'I!!iMt~,I!ial~il!W4
..~- "iii""
,
.... ,~ "'...
~
......
~ W ~ -4q.
:A) ~ '<(l 0 ~ :-0 ~ tv .....
~ :'- - c.,
It- ~ 6v ~ C .
0 ~ J:: ..0 .
Q. 0 C 0 () 0 (") c:o 9,
..... I I 0 c:
- ~ I g U) --!
..... ""'0(;:. rn
\'" '1 ~ {f -0 rpc:~ -0 '" -,"
~ --
, ~ .. ~-,. ~ ~-n
(' r ~~-
~ ~ ... ... p: G0~"7' -')C?
co
!6 <v ~ ... --< ;-?' ":.~~ (:)
... r,;;::c; ~v ", "
() PC) 'c ....,.,
- ~ .,d<o. ~2("')
, ~ ... ?': Co
3",;:;.r"
J>c :~~ ~
.... ___I
::--:': ':.51 -,.;
::;2 51
c:) -,
-. -~'---
- =~,
~ ,. ~,~.,
~~ 0' .
-",-,"'
-
;
.'-
-
.~ ,I". '
_~~~',' ,L_ , ""
"w,
· . 1 '
GE Cap1ta Mortgage Serv1ces, Inc.
Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
Vs.
Ollie B, Martin III
Tamilla A. Martin
Defendants
NO, 01-3763-Civil Term
AFFIDAVIT PURSUANT TO RULE 3129.1
GE Capital Mortgage Services. Inc., Plaintiff in the above
action, by its attorney, Joseph Goldbeck, Jr., Esquire, sets forth
as of the date the Praecipe for the Writ of Execution was filed
the following information concerning the real property located at
6 Koser Road. Shippensburg. PA 17257.
1. Name and address of owner (s) or reputed owner (s):
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
Ollie B. Martin III
758 Shippensburg Road
Newville. PA 17241
Tamilla A. M~rtin
30 Oak Hill Road
Carlisle. PA 17013
2. Name and address of defendant(s) in the judgment:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
SAME AS ABOVE
3. Name and address of every judgment creditor whose judgment
is a record lien on the real property to be sold:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
Cumberland Cn. Adult Probation
Courthouse Square
Carlisle. PA 170]3-3387
4. Name and address of the last recorded holder of every
mortgage of record:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
l'Ilme
,i~'-~""""'-
~~"""""
, ih'"
'-.i!su.,;w, I
.c.. 5.
Name and address of every other person who has any record
lien on the property:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
Hone
6. Name and address of every other person who has any record
interest in the property and whose interest may be affected
by the sale:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
Cumberland County D~t_ of
Domestic Relations
P.O. Box 320
Carlisle. PA 17013
Pa D~t_ of Public Welfare
Bur~au of Chi1d ~~port Enforoem~nt
Health and Welfare B1qq. Room 432
P.o. Box 2675
Harrisburg. PA 17105
7. Name and address of every other person of whom the
plaintiff has knowledge that has any interest in the
property that may be affected by the sale:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
Hone
I verify that the statements made in this affidavit are true
and correct to the best of my personal knowledge or information
and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. #4904 relating to unsworn
falsification to authorities.
September 11, 2001
~~~iDI!tthW"-$;;",-,';tI1"'iM~fl:~'~Jj%\~,",,;';>R.oknlk'<::;C',,":'J"d"o"Y;'-';,''''
.r,!.llJIILlJIIIlI
~
._""
. ~ ,,",-=..~ ,~""w 'C~,'" c.~ _ ~o,_ ~~_ _~^,
*" ~".'"~?,, -~, ~ -~."~<,~
""~",""_"j",-""."-,i:l4'!!@'-"i!~~~iiill:"'~""'!1oi,,.l:,.--""&\l!\1'~I~'WOIi~Iii' ""....~'~
~~
()
S
~:,.~
""'CJ 6:J
nlfT'1
~1~
);;:; -..,
2""(.."
~'O
J"C
~
ij~'
'I
"'''
.
o
C)
"
[/)
Pi
""U
..
1'-:::::
OJ
,.:::-.5
-0
-"'-
..:.~: ("')
------!---l1
~2C'5
O,Tl
~
::0
-<
(,,)
Ul
<::0
~w~ ~
-
< ~ ~
'" ~,;. ,,'I ,Co,
~ ~ -- I al.::.LIJ
GOLDBECK, MCCAFFERTY & MCKEEVER
By: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 500-The Bourse Bldg.
III S. Independence Mall East
Philadelphia, PA 19106
(/.1 <;) 6/.7-13/./.
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
GE Capital Mortgage Services, Inc.
Vs.
CUMBERLAND COUNTY
CIVIL DIVISION
NO. 01-3763-Civil Term
Ollie B. Martin III
Tamilla A. Martin
CERTIFICATION
JOSEPH A. GOLDBECK, JR., ESQUIRE, hereby states that he is
the attorney for the Plaintiff in the above captioned matter and
that the premises are not subject to the provisions of Act 91
because it is:
(X) an FHA Mortgage
( ) non~owner occupied
( ) vacant
( ) Act 91 procedures have been fulfilled
This certification is made subject to the penalties of 18 Pa.
C.S. ~ 4904 relating to unsworn falsification to authorities.
oldbeck, Jr,
or Plaintiff
-,,' ,
. . ,~ .-
~" . ~,' '--'. . - '-,~
" "~.1:
'"
filii .
,., GOLDBECK MCCAFFERTY & McKEEVER
By: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
(?1 <;) fi?7-1::l??
ATTORNEY FOR PLAINTIFF
GE Capital Mortgage Services, Inc.
Plaintiff
: CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
Vs.
Ollie B. Martin III
Tamilla A. Martin
Defendants
NO.01-3763-Civil Term
NOTICF. OF SHERIFF'S SALE OF REAL ESTATE
TO: Tami11a A. Martin
30 Oak Hill Road
Carlisle, PA 17013
THIS, FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A
DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO
BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF
A LIEN AGAINST PROPERTY.
Your house (real estate) at 6 Koser Road. Shippensburg. PA
17257. is scheduled to be sold at the Sheriff's Sale on
DecAmher 5. 2001 at 10:00 a.m., in Cumberland County, Cumberland
County Courthouse, Commissioners Hearing Room, 2M Floor, Carlisle,
PA 17013 to enforce the court judgment of S72.155.10 obtained by
GE Cqpita1 Mortgage Services. Inc. (the mortgagee) against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate
action:
1. The sale will be cancelled if you pay to the mortgagee the
Back payments, late charges, costs and reasonable attorneys
Fees due. To find out how much you must pay, you may call:
(215) 627-1322
2. You may be able to stop the sale by filing a petition asking
the Court to strike or open the judgment, if the judgment
was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may also be able to stop the sale through other legal
proceedings.
0",,';, ",
,
~~f'
~
"
You may need an attorney to assert your rights. The sooner
you contact one, the more chance you will have of stopping the
sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale
sold to the highest bidder.
calling (215) fi/.7-]~/./.
is not stopped, your property will be
You may find out the price bid by
2. You may be able to petition the Court to set aside the sale
if the bid price was grossly inadequate compared to the value of
your property.
3. The sale will go through only if the buyer pays the Sheriff
the full amount due in the sale. To find out if this has
happened, you may call the Sheriff's office at (717) /.40-fi~90.
4. If the amount due from the Buyer is not paid to the Sheriff,
you will remain the owner of the property as if the sale never
happened.
5. You have the right to remain in the property until the full
amount due is paid to the Sheriff and the Sheriff gives a deed to
the buyer. At this time, the buyer may bring legal proceedings to
evict you.
6. You may be entitled to a share of the money which was paid
for your house. A proposed schedule of distribution of the money
bid for your house will be prepared by the Sheriff within 30 days
of the Sale. This schedule will state who will be receiving that
money. The money will be paid out in accordance with this
schedule unless exceptions (reasons why the proposed distribution
is wrong) are filed with the Sheriff within ten (10) days after
the posting of the Schedule of Distribution.
7. You may also have other rights and defenses, or ways of
getting your home back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17103
(800) 990-9108
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17103
(717) 243-9400
,.
.
,.~
'~, '
,:d,
GOLDBECK McCAFF~RTY & McKEEVER
BY: Joseph A. Goldbeck., Jr.
Attorney I.D.#161~2
Suite 500 - The Bourse Bldg.
III S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
GE CAPITAL MORTGAGE SERVS. INC.
4680 Hallmark Parkway
San Bernardino, CA 92407
Plaintiff
vs.
OLLIE B. MARTIN III AND
TAMILLA A. MARTIN
6 Koser Road
Shippensburg, PA 17257
Defendants
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 01-3763 (Civil Term)
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P. 3129.2(c) (2)
Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby
certifies that service on the Defendants of the Notice of Sheriff Sale was
m~y:
(4) Personal Service by the Sheriff's Office:J lI1~ieulL _d._IL (copy of
return attached) Ollie.. +-Ta.I\'l.lLA. tnMf1/1Su..ed 10/1 bIoI fu jO~ e. ShG--,H1-])e p r
( ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal
return receipt attached) .
certified mail by Sheriff's Office.
Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for
Defendant(s) of record (proof of mailing attached).
Acknowledgment of Sheriff's Sale by Attorney for Defendant(s) (proof
of acknowledgment attached) .
Ordinary mail by Sheriff's Office to Attorney for Defendant(s) of
record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
( ) Premises was posted by Sheriff's Office/competent adult (copy of
return attached).
certified Mail & ordinary mail by Sheriff's Office (copy of return
attached) .
Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original
receipt(s) for Certified Mail attached).
Pursuant to the Affidavit under Rule 3129 (copy attached), service on all
lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck,
Jr., Esquire (copies of proofs of mailing attached).
The undersigned understands that the statements herein are subject to the
penalties provided by 18 P.S. Section 4904
-'~-
~ ,,---,",,~;,-~,""-"--;;:-:""~=
nolo 11575 :LC'\lI 1110\111 071010
, .
, '
TO:OlLlc B. MARTIN 1\I
758 Shippensburg ROild
Newvllle, PA 17241
SENDER:
COLDBECK MCCAFFERTY & McKEEVER'
september 11, 2001
REFERENCE:
MARTIN III,OLLIE B, 1
OCMS-OS20
PS Fo 3800 Jun 2ooil21 S/01 -
rm .
RETURN Postage
RECEIPT Certified Fee
SERVICE Return Receipt Fee
Restricted Delivery
.. Total Po~ge.& F:~ .,
US Postal Service PO~l'lktR()~\
Receipt for ~' '.t~;"..
11 ~t
,~ .
( ';., , JJ..:
Certified Mail ,.:2'" '
" "''''''''./'''~ I
No Insurance Coverage provided " ,~~
Do Not Use for InternatIonal Mail ....
-- .---.- ---"~~--.- - - .-- '- ~.----,_. -
- --.- ~.~--~~_._,
'-'.~--'<;.-~
',-.-,;.-:;:-.".".---~~
neb 11575 ]'2"1~ IIltpll.D7~3
TO:rAMlllA A. MARTIN
30 Oak Hill Road
Carlisle, PA 17013
SENDER:
REFERENCE:
GOLDBECK MCCAfFERTY & McKEEVER.
September 11, '2001
MARTIN 1II,0LLlE B. 1
OCMS-oS20
PS Form 3800 J 2~21 S/01 .
un.
RETURN Postage
RECEIPT Certified Fee
SERVICE
Return Receipt Fee
Restricted Delivery
Total Pos~ ?tf~.
US Postal Service POSTM!\R~OFi, BATE.,;,\
Receipt for /:/oi/l"' '}'::f'o
I'" \ .
Certified Mail '~~
l ":,:",
':,\
No Insurance Coverage Provided l....,-~" vi' (
'" :-...,'". ,/
Do Not Use lor Inlernatlonal Mall _~. ~.,.' F
---
~
"3
(/\
I
~
q.;
o
3
OJ
""\
1T
)
'-
o
-
-
(0
u;
"
o
3
'"
'"
""
""
i
'"
<0
'"
o
o
3
'"
.
!!
ci
'"
~
;l,
.
""
:;
?'
Q
OJ
~ ~~~if%Q';!
'J5.~~~~~~
_ ~~~~4>.... ~
a 0...".,(-,;.. c: ~ 0-
'"'0 ~!:l~...~?;i~
ell ~3~~ai.l2:
::J f$if;t052~
E8'~?IDg,g
aii:~;i=go
!-Q.i~~s.~
. gg~9.~~
~(.~ ;.~..
~~3o'3;j;
. t.l--8=~
. a ~ c
g~3 ~!
5:'2.'10.0
~:r~~2~
!,,!1I~~
::J'" tr~~3
!!.=.::J 41
3~.1l3:'
_:;,,,,' 0.0
:.='oli;l!l;~
~~b.~~
~.!l.g3'3s
i!:g~~:~
:r~d3~...
i~q3~g
=.~-A.~
~ ~i~'2i
::T~3~3~
.~.-"lt
~ ;p'::~.a.;:
".11 = -g ~ 0-
.t~La~o~
"QQ..=l:u::J?,
~o;:o.~;!
gg~3~m
-:3g:!rg~
<) ~::lv 5"~
(I)" !!-;jl1l1l 3
Ii' t/.I'O <II ~ c
a:2C11'::J~
es-9Ii:gfi
a.iiif==iir~
lf~ 0:: 3 (,oOl.::l
=~~a~q
.e~~ ~gi
~ ~~~'O ~
o.:::o..~~
r~
.0
m-iil'
~."
~z
~c
",3
~~
:}g,
'"
"
o
.
.
J)-f
.0
g[
<z
. c
a3
!!tg
",
00
. -
-"
~~
o.
. .
iJ
o
~
~
"
~
:i
~
.
o
i
"-
<l
.
~
"
..
~
~
m
~
.".
,
~
'"
~
IV
~
~
~
o
.,,,,<...
~gi
~~""
BO!!!
. ,,-
~~~
-"'()
...."'~ 0
s .
'f >
~ ~
~ ~
g"
".
o
"
;1;
,
.
-
<D
())
m
".
'"
-..
n'"t:lt;HJ
g,9U
~1Sl~g'
~ ><..... \:l..
~~~~
:::iorrQ
o .....
W ~ t1
~
o
."
()~-J
g,~~
~~;;f
;'E!!>
>-'
-;;is:
-...J" :l
8 ~6'
~
:z....O
.~-
."'::
., ",.
=:i:Tl;CI
F:g' ~
>O.~
>iii;;
.-g'tl'
jj~ ~
.. -
-'"
o
!C
,
0'0
:!'" ;:.Jf.
o"''ll~
"'..."
I. Ill"
t; <::> (;f, ..
!;j~.
l<:::>OfJ,~,
Cj, I') ~
", <:Il
..., '" . .
....0 "'...
'0 ... ...,
..... ..... ... ....
:1:1 I
L
'"
IV
==:-O:I:IJJ""rJ
9 0 ~,,>
~~~gg
" " ~ 0 l'
~ t-.J 0.::;::0
'"0 0\ ::E ,~ ...,
;:t>-~G[~
.- ;:;!:\.e:
-4 eJ 00_.
.... (\l!: 0
~ E:l~ ~
Po 0 a.
"'''s>
, '" a
~g,
. ~
,,0
~a
o
a
~
-
".:'"
r
5
.
~?;
30"
~;p
5'..)>~
"'''-3
.. ~jf)
~ . "
-."
~(IIo.
V g
;ll...r.n5
=~d~
g,,,,W()
~9><J1~
~l~~~
S o.&,
~~
p~:;!
1O &=== tXI R>
g,~
~ii~
~
,.
~
~
!
.
.
z
.
.
~
th
;/
:-
~
~
~
o
r;
~
::
-
" 0
~ OOOOif
..
Q
.
(}~~~~
oo::cau,,<
o..~u
n.ot-m
d; .. 0
~
~
.
.
3
!>>.
:JOOO~
0'"
~~
"
'"
.5
Q
~~~~
;;u~~
Odl~:J
:;,5la.)J
~~ g
g "if
" 33
t3 ~
9 Q
"
~
~
"
.
~
a
0;"
.
,.
~!l
"=C
,,"
'<
",.
-c
.
<'
0-
e'
. .
""
o
_c
-.
Oth
O.
0&
~
-
:~
",.
00 if",
z S ~~
S. . cr iii"
II; . lit
~! o~
~ ~ Q.
~ ~
",
~a ;tg~)>
.. 0 fA _ ~
g~&<Ac
:~ :=~as-
Q:5'3
~OJ"'O
~.~~;J gtt~
-.. .0:;'
~:'i --~
"ll(l1g,~.g3-
: 0 ~""" lF~'~'
o ~ In 5~
~,,~.Q, Q.~ 0-
dl 0 ~
.,.
;n
.
3
o
fi
~
J_" ^^
"^' .1;
GE Capital Mortgage Services, Inc.
Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
Vs.
Ollie B. Martin III
Tamilla A. Martin
Defendants
NO. 01-3763-Civil Term
AFFIDAVIT PURSUANT TO RULE 3129.1
GE Capital Mortgage Services. Inc., Plaintiff in the above
action, by its attorney, Joseph Goldbeck, Jr., Esquire, sets forth
as of the date the Praecipe for the Writ of Execution was filed
the following information concerning the real property located at
6 Koser Road. Shippensburg. PA 17257.
1. Name and address of owner(s) or reputed owner (s):
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
Ollie B. Martin III
758 Shippensburg Road
Newville. PA 17241
TAmilla A. Martin
30 Oak Hill Road
Carlisle. PA 17013
2. Name and address of defendant (s) in the judgment:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
SAME AS ABOVE
3. Name and address of every judgment creditor whose judgment
is a record lien on the real property to be sold:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
Cumberland Co. Adult Probation
Courthouse Square
Carlisle. PA 17013-3387
4. Name and address of the last recorded holder of every
mortgage of record:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
~
~~'" ' ~"" > -,
^'...,
LcJ
5. Name and address of every other person who has any record
lien on the property:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
:tiQ.ne
6. Name and address of every other person who has any record
interest in the property and whose interest may be affected
by the sale:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
Cumberland County Dept. of
Domestic Relations
P.O. Box 320
Carlisle. PA 17013
Pa Dapt. of Public Welfare
Bureau of Child S~ort Enforcement
Health and Welfare Bldg. Room 432
,P.o. Box 2675
Harrisburg. PA 17105
7. Name and address of every other person of whom the
plaintiff has knowledge that has any interest in the
property that may be affected by the sale:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
:tiQ.ne
I verify that the statements made in this affidavit are true
and correct to the best of my personal knowledge or information
and belief, I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. #4904 relating to unsworn
falsification to authorities.
September 11, 2001
ldbeck, Jr.
r Plaintiff
1it~~ll1iG~ji!;J~'~m'oa<1fJ8~~~"k,liii">.:.~.~",,,~~,,;"":d'-';-,~" -I,,,'I-"'r'''!'.t<''"''~!:__
.,- " ~"'
,~ ~, -,
"'-"1
If~~__'
'D 0 d.
,~
'- ':')
-r.;i'
~l~~~ d)
,-.01
;;..:r- , J
CO }. LO
--C'
r:c' CJ
::r:'-' .." .';-1,
zO -j',: ;.~-n
--CJ \.-?,")
>c:: '6' om
33 N ~
-, (J1 -<
rI
,
GE Capita! Mortgage Services, Inc.
VS
Ollie B. Martin III and Tamilla A. Martin
~ " ,;. ,)."." II; "'""""""*"",.",,j
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2001-3763 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED pursuant to instructions from Attorney Joseph A. Goldbeck.
Sheriffs Costs:
Docketing
Surcharge
Posting Handbills
Law Library
Prothonotary
Share of Bills
Mileage
Levy
Advertising
Certified Mail
Poundage
Postpone Sale
Law Journa!
Patriot News
30.00
30.00
15.00
.50
1.00
25.66
23.40
15.00
15.00
2.45
12.42
237.50
225.60
$633.53 paid by attorney
Sworn and subscribed to before me
tv
This .l.9-dayof ~
2001, A.D. O-r- (l ~/~.
Prothonotary
so~, ~
~ '1...(; ~.r -4'
.
R. Thomas Kline, Sheriff
Byf2~ Jrndh
R a! Estate Deputy
l.1"C-k 3l) jlri)
Rw. i!9;~
. ~
, ~ ~,~
~ t,f,
....
GE Capi tal Mortgage Service,s j IZ\C .
Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
Vs.
Ollie B. Martin III
Tamilla A. Martin
Defendants
NO. 01-3763-Civil Ter.m
AFFIDAVIT PURSUANT TO RULE 3129.1
GE Cqpita1 Mortgage Services. Inc., Plaintiff in the above
action, by its attorney, Joseph Goldbeck, Jr., Esquire, sets forth
as of the date the Praecipe for the Writ of Execution was filed
the following information concerning the real property located at
6 Koser Road. Shippensburg. PA 17257.
1. Name and address of owner(s) or reputed owner (s):
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
Ollie B. Martin III
758 Shippensburg Road
Newville. PA 17241
T~mi11a A. Martin
30 Oak Hill Road
Carlisle. PA 17013
2. Name and address of defendant(s) in the judgment:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
SAME AS ABOVE
3. Name and address of every judgment creditor whose judgment
is a record lien on the real property to be sold:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
~11mber1and Co. Adult Probation
Courthouse S~are
Carlisle. PA 17013-3387
4. Name and address of the last recorded holder of every
mortgage of record:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
HQne
, . , "~"
". '~', 'Il"";""'tiill.,;>hol
"
5. Name and address of e~ery qther person who has any record
lien on the property:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
Nl:me
6. Name and address of every other person who has any record
interest in the property and whose interest may be affected
by the sale:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
Cumbe~land Coun~y Dept. of
Domestic Relations
P.O. Box 320
Carlisle. PA 17013
Pa Dp~t. of Public Welfare
Bure~'~ of Child S~port Enforcement
Health and Welfare Bldg. Roam 432
P.o. Box 2675
Harrisburg. PA 17105
7. Name and address of every other person of whom the
plaintiff has knowledge that has any interest in the
property that may be affected by the sale:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
Nl:me
I verify that the statements made in this affidavit are true
and correct to the best of my personal knowledge or information
and belief. I understand that 'false statements herein are made
subject to the penalties of 18 Pa. C.S. #4904 relating to unsworn
falsification to authorities.
September 11, 2001
ldbeck, Jr.
r Plaintiff
-
09/19/2001 11:34 FAX 215 627 7734
GOLDBECK
.. '~''''' ~"',~;,
~ CtThlBERLAND SO
,
I
I4J 004
GOLDfECK McCAFFERTY & McKEEVER
By: coseph A, Goldbeck, Jr.
Atto2ney I.D. #16132
Suit, 500 - The Bourse Bldg.
111 t. Independence Mall East
Phil, delphia, PA 1910,6
J..2l5.: h 2 7 - 1..322
ATTORNEY
,
I
I
FOR
I
1
PLAINTIFF
GE C,pital Mortgage Services, Inc.
Plaintiff
CUMBERI.AND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
Vs.
011i', B. Martin III
'l'ami:.la A. Martin
Defendants
: NO.Ol-3763-Civil Term
NOTT~F. OF "'HF.RTFF',~ "'lU,1': ()F 1'11':1>-7, P,<;T1>-'fF. ,
TO: 'l'amilla A. Martin
30 Oak Hill Road
Carlisle, PA 17013
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A
DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO
BE AN ATTEMPT ,TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF
A LIEN AGAINST PROPERTY.
Your house (real estate) at n Koser Road. ~h~pp~nsh"Tg. PA
~~ is scheduled to be sold at the Sheriff's Sale on
~nbAr ~. 2001 at 10:00 a.m., in Cumberland County, Cumberland
Coun:y Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle,
PA 17013 to enforce the court judgment of $72.155.1,0 obtained by
IDLC.pita1 Mortgage "'p.'tV"ioe", Tne:!. (the mortgagee) against you.
NOTICE OFOWN"P.R'S RTGHTS
YOU MAV BE ABLF. TO PRF.VF.N'I' THIS RHF.RIFF' ~ ~A'I.E
,
To prevent this Sheriff's Sale, you must take immediate
acti::m;
1 The sale will be cancelled if you pay to the mortgagee the
Back payments, late charges, costs and reasonable attorneys
Fees due. To find ,out how much you must pay, ydu may call:
(215) 627-1322
2 You may be able to stop the sale by filing a petition asking
the Court to strike or open the judgment, if the judgment
was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3, You may also be able to stop the sale through other legal
proceedings. I
5EP 19 2001 12:53
215 527 7734
Pf'lGE.04
< ,
.
"'1i;,;,
09/19/2001 11:34 FAX 215 627 7734
GOLDBEC!(
.. CUllBERLAND SO
~005
You may need an attorney eo assert your rights. The sooner
you contact one, the more chance you will have of stopping the
sale. (See notice on page two on how to obtain an attorney.)
!
,
XQ!L MAY STIr.r. BE ABLE TO SAVE YOUR ,PROPERTY AND YOU RAVE OTRE'R
~ ITS EVl~N TF TRR SHERIFF'S SAYrF. n01ll1'l TAKE PLACE.
1. If the Sheriff's Sale
solei to the highest bidder.
cal: ing .L'<1 C;\ !,;?7-1"1??
is not stopped, your property will be
You may find out the pr~ce bid by
I
2. You may be able to petition the Court to set aside the sale
if 1.he bid price was grossly inadequate compared to the value of
yom' property.
3. The sale will go through only if the buyer pays the Sheriff
the full amount due in the sale, To find out if this has
haPl'ened, you may call the Sheriff's office at (717) 24n-!,;"IQO
4. If the amount due from the Buyer is not paid to the Sheriff,
you will remain the owner of the property as if the sale never
haPl 'ened.
5. You have the right to remain in the property until the full
amotnt due is paid to the Sheriff and the.Sheriff gives a deed to
the buyer. At this time, the buyer may bring legal proceedings to
evict you.
6. You may be entitled to a share of the money whicH was paid
for your house. A proposed schedule of distribution of the money
bid for your house will be prepared by the Sheriff within 30 days
of the Sale. This schedule will state who will be receiving that
money. The money will be paid out in accordance with .this
SchEdule unless exceptions (reasons why the proposed distribution
is ~,rong) are filed with the Sheriff within ten (10) days after
the posting of the Schedule of Distribution.
7. You may also have other rights and defenses, or
getting your home baCK, if you act immediately after
i
ways of
the sale.
YOU SHOULD TAXE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVI A LA~~R OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TEE OFFICE
LIS~BD EELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.'
CUmberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17103
(800) .9.90-.9108
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17103
(717) 243-9400
SEP 192001 12:53
215 527 7734
PriGE,05
, .
.~ ~;;"'_ ''''~<Q'",".,j,;,b
GOLDBECK McCAFFERTY & McKEEVER
By: Joseph A. Goldbeck, Jr.'
Attorney I.D. #16132
Suite 500 - The Bourse Bldg.
III S. Independence Mall East
Philadelphia, PA 19106
(:/.1 'i) 6:/.7-1322
ATTORNEY FOR PLAINTIFF
GE Capital Mortgage Services, Inc.
Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
Vs,
Ollie B. Martin III
Tamil1a A. Martin
Defendants
NO.01-3763-Civil Term
NOTTeR OF SHERIFF'S SALE OF RF.AL ESTATF.
TO: Ollie B. Martin III
758 Shippensburg Road
Newville, PA 17241
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A
DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO
BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF
A LIEN AGAINST PROPERTY.
Your house (real estate) at 6 Koser Road. Ship~ensburg. PA
17257. is scheduled to be sold at the Sheriff's Sale on
December 5.,2001 at 10:00 a.m." in cumberland County, Cumberland
County Courthouse, Commissioners Hearing Room, 200 Floor, Carlisle,
PA 17013 to enforce the court judgment of S72.155.10 obtained by
GE Capitsl Mortgage Services. Inc. (the mortgagee) against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate
action:
1. The sale will be cancelled if you pay to the mortgagee the
Back payments, late charges, costs and reasonable attorneys
Fees due. To find out how much you must pay, you may call:
(215) 627-1322
2. You may be able to stop the sale by filing a petition asking
the Court to strike or open the judgment, if the judgment
was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3, You may also be able to stop the sale through other legal
proceedings.
~""
,
~",,;;_;;-J'
You may need an attorney ~o assert your rights. The sooner
you contact one, the more chance you will have of stopping the
sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1, If the Sheriff's Sale
sold to the highest bidder.
calling (7.1S) 627-1~22
is not stopped, your property will be
You may find out the price bid by
2. You may be able to petition the Court to set aside the sale
if the bid price was grossly inadequate compared to the value of
your property.
3. The sale will go through only if the buyer pays the Sheriff
the full amount due in the sale. To find out if this has
happened, you may call the Sheriff's office at (717) 240-6~90
4. If the amount due from the Buyer is not paid to the Sheriff,
you will remain the owner of the property as if the sale never
happened.
5. You have the right to remain in the property until the full
amount due is paid to the Sheriff and the Sheriff gives a deed to
the buyer, At this time, the buyer may bring legal proceedings to
evict you.
6. You may be entitled to a share of the money which was paid
for your house. A proposed schedule of distribution of the money
bid for your house will be prepared by the Sheriff within 30 days
of the Sale. This schedule will state who will be receiving that
money. The money will be paid out in accordance with this
schedule unless exceptions (reasons why the proposed distribution
is wrong) are filed with the Sheriff within ten (10) days after
the posting of the Schedule of Distribution.
7. You may also have other rights and defenses, or ways of
getting your home back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
Cumberland County Bar Association
, 2 Liberty Avenue
Carlisle, PA 17103
(800) 990-9108
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17103
(717) 243-9400
-" ~ ~".<
fC,
.~--~~"'"t
GOLDBECK McCAFFERTY & McKEEVER
By: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
(215) 627-1322
ATTORNEY FOR PLAINTIFF
GE Capital Mortgage Services, Inc.
4680 Hallmark Parkway
San Bernardino, CA 92407
Vs.
Ollie B. Martin III
758 Shippensburg Road
Newville, PA 17241
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO 01-3763-Civil Term
Tamilla A. Martin
30 Oak Hill Road
Carlisle, PA 17013
ALL THAT CERTAIN piece or parcel of land situate in North Newton
Township, Cumberland County, Pennsylvania, more particularly
bonded and described as follows, to wit:
BEGINNING at a railroad spike in the center line of Township
Route 330 at corner of lands now or formerly of Dana L. Peterson
et ux; thence by said lands of Peterson, South 42 degrees 05
minutes 30 seconds West, 231.32 feet to an iron pin in the
property of lands now or formerly of W. Harold Yohe; thence by
said lands of Yohe, North 68 degrees 27 minutes 06 seconds West,
130.24 feet to an existing corner fence post; thence by same,
North 41 degrees 15 minutes 26 seconds East, 199.35 feet to an
iron pin; thence continuing by same, North 65 degrees 26 minutes
00 seconds West, 26.19 feet to an iron pin at corner of lands
now or formerly of Norman I. West; thence by said lands of West,
North 42 degrees 05 minutes 30 seconds East, 92.55 feet to a
railroad spike in the center line of said Township Route, South
45 degrees 14 minutes 37 seconds East, 150 feet to a railroad
spike, the place of BEGINNING.
Tax Parcel #30-11-0306-007A
Being known as 6 Koser Road, Shippensburg, PA 17257
-
" ~
,~
k"", ",I
'""--:W.~~~'
WRit OF EXECUTION and/or ATIACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 01-3763 CIVIL 1:5X TERM
CIVIL ACTION - LAW
TO THE SHERIFF OF
Cumberland
COUNTY:
GE Capital Mortgage Services, Inc.
To satisfy the debt, interest and costs due
PLAINTIFF(S)
from Ollie B. Martin III, 758 Shippensburg Road, Newville, PA 17241 and Tamilla A.
Martin, 30 Oak Hill Road, Carlisle, PA 17013
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell See Leqal 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 defendant(s) or otherwise disposing
thereof;
(3) If property ofthe defendant(s) not levied upon an subjectto attachment is found in the possession of anyone other
th,an a named garnishee, you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above
stated.
%
L.L.
Due Prothy
Other Costs
$.50
Amount Due $72,155.10
from 9/11/01 to sale date at
Interest :;;11.86 per dian.
Atty'S Comm
Atty Paid
$1.00
$130.30
Plaintiff Paid
Date: September 18, 2001
Curtis R. Long
Prothonotary, Civil Division
By.;.
~o--r~ P 7p-Ji~ r
Deputy
REQUESTING PARTY:
Name Joseph A, Goldbeck, Jr., Esq.
Suite 500-The Bourse Bldg.
111 G. Independence ID11 Baot
philadelphia, PA 19106
Address:
Attorney for: Plaintiff
Telephone: 215-627-1322
Supreme Court ID No. 16132
""""""<'c;,)";:<;<,,,!ii!:i~,,~~'~iliM,~1\i<1iif~8j;,~~.iillii[l6ifJlj@~~illi~~_'I~-.,~~~IDi&lMtlij6..
REAL ESTATE S,;LE No. SY
On September 19, 2001, the sherifflevied upon the
defendant's interest in the real property situated in North Newton
Township, Cumberland County, PA, known and numbered as
6 Koser Road, Shippensburg, and more fully
described on Exhibit "A" filed with this writ and by
this reference incorporated herein.
Date: September 19,2001
By:
gfJ cLct ~vvU:t(
Real Estate Deputy
~
~
~
6iii .
I
, ""~ .~ -,,,,~~
~,.,"_,~_"< _~~., ~".~ ,'~,"r.""~ ,,~ ". ._
" " ~ ., y,"
..--1 'tf">....
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
James L. Clark being duly sworn according to law, deposes and says:
That he is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing
under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818
Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The
Patriot-News and The Sunday 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 reguiar 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 ",mpowered 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 offjce for the Recording of Deeds in and for said County of DauP7 in Miscellaneous Book "M",
V;I~:Lll~:~~:~' - .......................~.,.~.....................................:......................
COpy S n to and subscribed before me . 19th day 0 ovem 2001 A.D.
SALE #54
Notarial Seal
Terry L Russell. Notary Public
Harrisburg, DauPhin County
My Commission Expires June 6, 2002
Member, Pennsylvania Association at Nota I
L
RY PlJBLlC
commission expires June 6, 2002
-"'=---"-'-~-R.cALrSTATE-SALe No:54"- -
co. Writ No. 2001-3763
'=' .~~ Civil Term
~:::::: Ge-Capilal Mortgage Services Inc.
'~ vs
:.:-- ~ Ollie B. Martin 111 and
- -"'~ Tamilla A. Martin
.'_ E Ally: Joseph Goldberg
;-.llESCRJl'TION -
,- ALL TtIAT.' CERTAIN pie:S or parcel of land
~t'u,a.te lliNorth Newton .;;owns~p, Cumberland
~COun(y-;-:-pennsylvania, r;)\Jre particularly bonded
!:sand-deit;tib.e_d..asJollows, to wit:
BEGJNNING at a railroad stake in the center line
~~fTovmship RQute 330 at comer of land$ now or
"_:Jormedy'_ of Dana L. Peteroon et ux; thence by
~Llarid$ of Peterson, South 42 degrees OS
~1~J)U_ei:JO seconds West, 231.32 feet 10 an iron
~ pin in tlic'property of lands now or formerly of W.
~llfQldyghe; thence by said lands of Yo be, North
:~:rde~, 27 minutes_ if6.seconds West, l30,~
:::-:-reeno ,an existing corner fence post; thence hy
~~~rlb 4[ degrees 15 minutes 26 seconds P bl. h ' R . f .
~__~:35f<<ttoanir~m.pjJj;!henrecO.!ltinuing. U IS er S ecelpt or AdvertiSing Cost
,~.=hvsa~.ty'NOrth65degr.ees2~mmute,OOseconds _ publisher of The Patriot-News and The Sundav Patriot~News newspapers of general
Sest, 4),.19 fcct to an tron pm at corner of lands . --- - ,.,., --- -- - ,
!nQw-oBbrmerly of Norman I. West; then~e by _9 receipt of the aforesaid notice and publication costs and certifies that the same have
,~~dJ@.!is"Qf West, North 42 degrees 05 mmutes
~O'second$East,92.5Sfeettoarailroad$pike,jn
, tlle cenICt: line of said T,?wnsliip Route, South 45
'~d~rees)4 minutes 37 se<-onds East, 150 feet to a
~toM~wike, the place of BEGINNING. __
0"~~ #30.II.o306.007A.
'~J:i- ~own as 6 Koser Road, Shippensburg,
l<I'AI1217. . ________________
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
$
$
$
224.10
1.50
225.60
By.................................................................... ___
.,-,~"",~"-~,,,,,, .
='
,..L.~~'."' '.." ' ,
~-~
~. ' ,
"'1 ~~'"~'e;:."J
, .
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 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 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
statements as to time, place and character of publication are true.
SWORN TO AND SUBSCRIBED before me this
26 day of OCTOBER. 2001
NOTARIAL'
LOIS E. SNYDER, Notary Public
CaltlsIe Bolo, Cumbel1and County
My Commlsalon Explr8s MaR:h 5, 2IlO5
-----'~-=_~"',.~,''''\'''''''_',d"'''..~JCM'''~,ell~~)~'',I,'''&,'''~'''" ""~' 'I."'",,,,,,",,' ". ""'-_~'~"'> ''','r.I~ih''''''L''~."'i,~^"j'; '-'<",<I["'.....-""'>lI>!Ilii!*Iii~:.Ml<lllllll~b:.,<Ii"","',.,~,~~~ 'it" ~&llIiil1 > ,
REAL ESTATE SALE NO. 54,
Writ No. 2001.3763 Civil
GE Capital Mortgage Services Inc.
vs.
Ollie B. Martin III and
Tam1lla A. Martin
Atty.: Joseph Goldbeck
ALL THAT CERTAIN piece or par-
cel of land situate in North Newton
Township, Cumberland County.
Pennsylvania, more particularly
bonded and described as follows,
to Wit:
BEGINNING at a railroad spike
in the center line of Township Route
330 at corner of lands now or for-
merly of Dana L. Peterson et ux.;
thence by said lands of Peterson,
South 42 degrees 05 minutes 30
seconds West, 231.32 feet to an iron
pin in the property of lands now or
formerly of W. Harold Yohe; thence
by said lands of Yohe, North 68 de-
grees 27 minutes 06 seconds West,
130.24 feet to an existtng comer
fence post; thence by same, North
41 degrees 15 minutes 26 seconds
East. 199.35 feet to an 1ron pin;
thence continuing by same, North
65 degrees 26 minutes 00 seconds
West. 26.19 feet to an iron pin at
comer of lands now or fonnerly of
Norman 1. West; thence by said
lands of West, North 42 degrees 05
minutes 30 seconds East, 92.55
feet to a ratlroad spike in the center
line of said Township Route, South
45 degrees 14 minutes 37 seconds
East. 150 feet to a railroad spike,
the place of BEGINNING.
Tax Parcel #30- Il-0306-007 A.
Being known as 6 Koser Road,
Shlppensburg, PA 17257.
.
'="IiIO~
,
> ~
,,"c<
.~;,"" " " '"Je
<'t
)'
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P. 3180-3183
GE CAPITAL MORTGAGE
SERVICES INC,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
Plaintiff
NO: Ol-3763-Civil Term
VS.
TAMILLA A. MARTIN
OLLIE B, MARTIN, III
Defendants
PRAECIPE FOR WRIT OF EXECUTION
(MORTGAGE FORECLOSURE)
TO THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due
Interest from 9/11/01 to sale
date at $11.86 per diem
Total
$72,155.10
Plus Costs
dbeck, Jr.
Sui 500- e Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
Attorney for Plaintiff
Note: please attach description of property.
:itII~1li1~~'.i!l"11illJrgi€'-lJil~*i~K'Ei;1i,.1~1~'m,~,ili'm1lbw)",~~,~"~",,,j-~,c'1'.,",~'_"";h'_;:''',rt"",;..",,,j ""l<JiIU--"",,!;j1~"t!I~"-_'
.."',~
~I
1>0.0:
OH
~~
I!il..:l
..:ll>l
PlrJl
z~
jre
o '
Ul>l
[:;~
o
E-oU
~~
I!il~
:':I!il
;~
..:
Co
Co
Co
'"
'.
f!
01
E-'
~I
-rl
~.
'rl
1:.1
,
<"
<Co
[-.
<"
I
~I
e,
CI
Zi
U
Z
H
rJl
I!il
U
H
f:i
I!il
rJl
I!il
t!l
t3
E-o
~
~
..:l
.0:
E-o
H
PI
.0:
U
I!il
t!l
~.
&
~
~
111
:>
H
ZH
HH
E-o ,
~Z
~H
E-o
,~
.o:~
.0: ,
~Pl
HI!il
~H
E-o~
o
."~ ,dlll'~, ' ~'~ "~~
z
o
H
~ ~,
U G)
I!il k
~ ::l
I!il 111
o
1>0.-1
o U
G)
E-o k
H 0
~I>o
G)
~ tn
o III
1>0 tn
....
I!il k
PI 0
H::e:
U~
I!il
i:i
PI
..
"d
Q)
r-i
'r!
""
.J
,~
~
,W
'W
~.
~ ~ ". 0
W ?'\ 11\, ~ :<:. A! (~,
. . l1I, '" " "
Y\\:\"'\!,~" :\
tv \:) \" \) ;:t: '\\) "-
J ~ ~ (5
't:l
~
s~
~~
~11:0
,"" ,-;,.
'\J X-}
..... ,\:.
~ ~
.,
r~
'tl0
Illr-
0.-1
~.o:
.-IPl
.-I
-r! '
:.: CP
.-I
..I<: fQ
cd ".-1
o ri
k
o III
Mt)
o
.w
.w
.0:
Ul
Ul
Q)
><
"d
~
c"
S::.~
...c__
raF~
<"-'-"-
~F
~~~
=::3
-,
'tl
III
o
~....
~
tnN
kr-
::Sri
{l.o:
R PI
G)
PI '
PIG)
.r! ....
,<:I....
rJl-r!
<Xl ~
Ll1 G)
r--l!;
"~'1
<--','1
G:J
N
c....";
'"
"'\:
\
"d
Q)
~
><
Q)
Ul
Q)
..Q
;:.,
g
Ul
><
Q)
P<
nS
P<
Q)
><
Q)
..c:
""
C-',
,:-:j
4,>
::0
-;;
'tW
".--
--~
.' ~ ~',.,
.'c
~._, .
o <'~<"l
lo,
GOLDBECK McCAFFERTY & McKEEVER
~Y: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
GE CAPITAL MORTGAGE SERVICES INC.
4680 Hallmark Parkway
San Barnardino, CA 92407
Plaintiff
IN THE COURT OF COMMON PLEAS
Vs.
of Cumberland County
CIVIL ACTION - LAW
TAMILLA A. MARTIN
OLLIE B. MARTIN, III
(Mortgagors and Record Owners)
6 Koser Road
Shippensburg, PA 17257
Defendants
ACTION OF MORTGAGE FORECLOSURE
Term No. Ol-3763-Civil Term
AFFIDAVIT PURSUANT TO RULE 3129
GE CAPITAL MORTGAGE SERVICES INC., Plaintiff in the above action, by its
attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe
for the writ of execution was filed the following information concerning the real
property located at:
6 Koser 'Road Shippensburg, PA 17257
l,Name and address of Owner(s) or Reputed Owner(s):
TAMILLA A. MARTIN
30 Oak Hill Road, Carlisle, PA 17013
OLLIE B. MARTIN, III
758 Shippensburg, Road Newville, , PA 17241
2. Name and address of Defendant(s) in the judgment:
TAMILLA A. MARTIN
30 Oak Hill Road, Carlisle, PA 17013
OLLIE B. MARTIN, III
758 Shippensburg Road, Newville, , PA 17241
. Name and last known address of every judgment creditor whose judgment is a record
lien on the property to be sold:
PA DEPARTMENT OF PUBLIC WELFARE -
Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320, Carlisle, PA 17013
Cumberland Co. Adult probation
Courthouse Square, Carlisle, PA 17013-3387
I ,,,-,,,,
,,-"
;,)'"
. c, ~""~
to,.
4. Name and address of the last recorded holder of every mortgage of record:
.
Members First Federal Credit Union
5275 E. Trindle Road, Mechanicsburg, PA 17055
5. Name and address of every other person who has any record interest in or record
lien on the property and whose interest may be affected by the sale:
6, Name and address of every other person of whom the plaintiff has knowledge who
has any record interest in the property which may be affected by the sale.
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.
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to
the best of my personal knowledge or information and belief. I understand that
false statements herein are made subject to the penalties of 18 Pa, C,S. Section
4904 relating to unsworn falsification to authorities.
DATED: February 7, 2002
Y & McKEEVER
eph A. G dbeck, Jr., Esq.
y for Plaintiff
GOLDB
BY: J
Attor
-
" "
~,--,,"
C"
''''';,. ,', "'",.
\>>,,-
JQspeh A. Goldbeck, Jr.
Attorney I.P. #16132
Suite 500 - The Bourse Bldg.
III S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
GE CAPITAL MORTGAGE SERVICES INC.
4680 Hallmark Parkway San
Barnardino, CA 92407
Plaintiff
IN THE COURT OF COMMON PLEAS
of Cumberland County
Vs.
CIVIL ACTION - LAW
TAMILLA A. MARTIN
OLLIE B. MARTIN, III
(Mortgagors and Record Owners)
6 Koser Road.
Shippensburg, PA 17257
Defendants
ACTION OF MORTGAGE FORECLOSURE
TERM NO. 01-3763-civi1 Term
CERTIFICATION AS TO THE SALE OF REAL PROPERTY
I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am the
attorney of record for the Plaintiff in this action, and I further certify
that this property is subject to Act 91 of 1983 and. the Plaintiff has
complied with all the provisions of the Act.
Jos
Att
0"
<
.,' 't .;.,
~
- '~'
"\
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney LD.#16132
Suite 500 - The Bourse Bldg.
I I I S. Independence Mall East
Philadelphia, PAl 91 06
215-627-1322
Attorney for Plaintiff
GE CAPITAL MORTGAGE SERVICES INe. IN THE COURT OF COMMON PLEAS
4680 Hallmark Parkway
San Barnardino, CA 92407 of Cumberland County
Plaintiff
Vs. CIVIL ACTION - LAW
TAMILLA A. MARTIN ACTION OF MORTGAGE FORECLOSURE
OLLIE B. MARTIN, III
(Mortgagors and Record Owners) Term No. 01-3763-Civil Term
6 Koser Road
Shippensburg, PAl 7257
Defendants
TillS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. TillS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: MARTIN, TAMILLA A.
TAMILLA A. MARTIN
30 Oak Hill Road
Carlisle, PA 17013'
Your house at 6 Koser Road, Shippensburg, PA 17257 is scheduled to be sold at Sheriffs Sale on
Wednesday, June 05, 2002, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the
court judgment of$72,155.1O obtained by GE CAPITAL MORTGAGE SERVICES INe. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT TillS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
I. The sale will be cancelled if you pay to GE CAPITAL MORTGAGE SERVICES INC., the back
payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call:
215-627-1322
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
- _' '''h_';_
'..,,"
"t
',.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
yOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fmd
out the price bid price by calling the Sheriff of717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriffthe full amount due in the sale. To find
out if this has happened, you may call the Sheriff of717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5 . You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share ofthe money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the
Sheriff's Sale. This schedule will state who will be receiving that money. The money will be paid out in
accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed
with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, P A 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, P A 17013
~
'.'
"
.
, ~"j
,
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
III S.lndependence11illlEa~
Philadelphia, P A 19106
215-627-1322
Attorney for Plaintiff
GE CAPITAL 110RTGAGE SERVICES INC. IN THE COURT OF COM"MON PLEAS
4680 Hallmark Parkway
San Barnardino, CA 92407 of Cumberland County
Plaintiff
Vs. CNIL ACTION - LAW
TA11ILLA A. IVlARTIN ACTION OF 110RTGAGE FORECLOSURE
OLLIE B. l\1AR TIN, III
(lVIortgagors and Record Owners) Term No. 01-3763-Civil Term
6 Koser Road
Shippensburg, P A 17257
Defendants
TillS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEl\fPTING TO
COLLECT A DEBT. TillS NOTICE IS SENT TO YOU IN AN ATTEl\fPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FR011 YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: MARTIN, III, OLLIE B.
OLLIE B. MARTIN, III
758 Shippensburg Road
Newville" PA 17241
Your house at 6 Koser Road, Shippensburg, P A 17257 is scheduled to be sold at Sheriffs Sale on
Wednesday, June 05, 2002, at 10:00 Al\I!, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the
court judgment of$72,155.10 obtained by GE CAPITAL 110RTGAGE SERVICES INC. against you.
NOTICE OF OWNER'S RIGHTS
YOU l\1A Y BE ABLE TO PREVENT TillS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be cancelled if you pay to GE CAPITAL 110RTGAGE SERVICES INC., the back
payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call:
215-627-1322
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
.,,,,,
..
,
,
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
you MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of717-240-6390.
2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of717-240-6390.
4, If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6, You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the
Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in
accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed
with the Sheriff within ten (l0) days after the schedule of distribntion is filed.
7 . You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
yOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIA nON
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, P A 17013
"
-
-> ^
iiL~~"l-,
GOLDBECK McCAFFERTY & McKEEVER
By: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
(215) 627-1322
ATTORNEY FOR PLAINTIFF
GE Capital Mortgage Services, Inc.
4680 Hallmark Parkway
San Bernardino, CA 92407
Vs.
Ollie B. Martin III
758 Shippensburg Road
Newville, PA 17241
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO 01-3763-Civil Term
Tamil1a A. Martin
30 Oak Hill Road
Carlisle, PA 17013
ALL THAT CERTAIN piece or parcel of land situate in North Newton
Township, Cumberland County, Pennsylvania, more particularly
bonded and described as follows, to wit:
BEGINNING at a railroad spike in the center line of Township
Route 330 at corner of lands now or formerly of Dana L, Peterson
et ux; thence by said lands of Peterson, South 42 degrees 05
minutes 30 seconds West, 231.32 feet to an iron pin in the
property of lands now or formerly of W. Harold Yohe; thence by
said lands of Yohe, North 68 degrees 27 minutes 06 seconds West,
130.24 feet to an existing corner fence post; thence by same,
North 41 degrees 15 minutes 26 seconds East, 199.35 feet to an
iron pin; thence continuing by same, North 65 degrees 26 minutes
00 seconds West, 26.19 feet to an iron pin at corner of lands
now or formerly of Norman I. West; thence by said lands of West,
North 42 degrees 05 minutes 30 seconds East, 92.55 feet to a
railroad spike in the center line of said Township Route, South
45 degrees 14 minutes 37 seconds East, 150 feet to a railroad
spike, the place of BEGINNING.
Tax Parcel #30-11-0306-007A
Being known as 6 Koser Road, Shippensburg, PA 17257
~~;iw'~I!iiliM-~;,)!;l1;';'''':1;l'ijW~hl2iit<~~!l!';h""Q;i.~'M:';:l''''';".
IJ1IH!IIIIUJ1!
.G~,ht'_~~.;I"'I,",,~id~,~ 'j,j' llll8'.....-
--
~~-
~ "'
. ~ ',^=^^
"~,
-
<:I
l~
-Coc'
n'1!"",
Z:-1"
Zc.
~~f~.
r::'C..
~:c:;
j;:~~
~
-
C.:>
1-'...,)
--....
~~'n
I":SJ
~<:)
r:-?
c.;)
1'1<1
" <
~~, , 0-." -b' .; "'
"":i
GOLDBBC~ Mc~FERTY & McKEEVER
BY: Joseph A. ~oldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
GE CAPITAL MORTGAGE SERVICES INC.
4680 Hallmark Parkway
San Barnardino, CA 92407
Plaintiff
IN THE COURT OF COMMON PLEAS
of Cumberland County
Vs.
CIVIL ACTION - LAW
TAMILLA A. MARTIN
OLLIE B. MARTIN, III
(Mortgagors and Record Owners)
6 Koser Road
Shippensburg, PA 17257
Defendants
ACTION OF MORTGAGE FORECLOSURE
No. 01-3763-Civil Term
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P. 3129.2 (c) (2)
Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies
that service on the Defendants of the Notice of Sheriff Sale was made by:
~
( )
Personal Service by the Sheri.ff's Office,.....""...r_ ,~ 1_ ;--J:'.l '-".L .L....___.
,. . 1) .rerJ6ol~Sm'nt(l.shenH5 ~cc:. i7V1lt SEeliG> d..-1J-51 Od--.
Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return
receipt attached).
Certified mail by Sheriff's Office.
Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for
Defendant(s) of record (proof of mailing attached).
Acknowledgment of Sheriff's Sale by Attorney for Defendant(s) (proof of
acknowledgment attached) .
( ) Ordinary mail by Sheriff's Office to Attorney for Defendant(s) of record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
( ) Premises was posted by Sheriff's Office/competent adult (copy of return
attached) .
Certified Mail & ordinary mail by Sheriff's Office (copy of return
attached) .
Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original
receipt(s) for Certified Mail attached).
Pursuant to the Affidavit under Rule 3129 (copy attached), service on all
lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr.,
Esquire (copies of proofs of mailing attached) .
The undersigned understands that the statements herein are subject to the penalties
provided by 18 P.S. Section 4904.
Jr.
"j,,'
.".
."',_;,,_e,,'....c
71bO 3901 9844 b5531488
TO: MARTIN, TAMILLAA.
TAMILLA A. MARTIN
30 Oak Hill Road
Carlisle, PA 17013
SENDER:
GOLDBECK MCCAFFERTY & MCKEEVER
February 7, 200;1
REFERENCE: MARTIN, TAMILLA A.I GCMS-0520
06/05/02 - Cumberland
PS Form 3800 June 2000
RETURN Postage
RECEIPT Certified Fee
SERVICE
Return Receipt Fee
Restricted Delivery
Total Postage & Fees
US Postal Service
Receipt for
Certified Mail
No Insurance Coverage Provided
Do Not Use for International Mail
~--~->-~,,-~~-----~~-~-~-- ~~,..-"-.~~~ ,~---~~._--~--~_.---'--.~-.-.
71bO 3901 9844 b5531495
TO: MARTIN, III, OLLIE B.
OLLIE B. MARTIN, III
758 Shippensburg Road
Newville" PA 17241
SENDER:
GOLDBECK MCCAFFERTY & MCKEEVER
February 7, 2002
REFERENCE: MARTIN, TAMILLA A.I GCMS.0520
06/05/02 - Cumberland
PS Form 3800 June 2000
RETURN Postage
RECEIPT Certified Fee
SERVICE
Return Receipt Fee
Restricted Delivery
Total Postage & Fees
US Postal Service
Receipt for
Certified Mail
No Insurance Coverage Provided
Do Not Use for International Mail
"
..
.=t
,~
1::>='
~~
t'
o
~
o
~
c:
9
t:P
~
~
t
" .~"'._~' -
"
en
~ ~,
3
'"
'"
--I
:'
~
r~ ~ I,
. 0." ~ ~ ~ ~
. . '" A W ~ ~
u- IV ~ 0
~Z
~c
~3
.0
, ~
~~
"
.
"
~
,
<D
'"
'"
;u~
. 0
~ ;;;
, Z
. c
u 3
!e.:;:-
~,
~ 9..
o}l
3~
" .
. .
,
o
o
3
u
~
~
<T
'<
-f
'<
"
~
i
~
"
o
.
3"
~
~
~
z
.
3
.
'!.
~
"
"
5
~
"
3
~
f
,-.--.
,-
?'
~
.,-.
..
~ ~~&>~'l~~
" ::t :J ~ C <' _ e
o g.a;~~"'ic
~ a~~:;:g.j;:~
"'tI ~... ~;oCi'S"
G ~3~{,OOni: ~l------ -
:l ~)f~~o2~.
~g~?(I03_g
ai:~l3'g2.
~2.~3 :=-g,;:j
gg~2.~~
~ i>>~ ~~ ii"
: ~3 g'g i
.!'"SbS-~
o o.O&i
:>&;000.
i@:!.lj40
. ~.:t" ::0
3 ~vg !:,
~-l@.n
!P~ ~ij~
. = .
i~:;~ili
;'l!l~i~
l:-..~i~
< -oS".. if
iif!~f
~otao;
=' &. 2lQ
g5'3~3E
!!!:!..._Il.
~ ~ t=:(?' iil
...g..:'J~Q.
ii$tl~~
-<O!i'"a'"
~g:gg.;
"<:3'2 o~
.. fll'~..
Fit'" Ii:f
~f:1!5fi
ii__~_a5
i.:t-;.ri
IUfd
HP ~1I
.U l
i:=:_.l f
,--- ---
<D
.
,
'"
...,
m
'"
,
,.-i~'Y1"; ~
;:.;,:~ ,:;'
I I ~
k "'<'
l~ .. l\. , '0'
',"l ,,~~~ );~!
\. 'f;-~ >,"1
~ ' t1".
, :/ .
~'f; ~,.u\..
fo-
,~
I .~.,,_ ",' .~,...... '_J>l"-''''''',"C"",-.~''''''',"
~ f w ~ ~
f -/
~.i~
;;;.;::~
~DOp.
~ ~ c::
:-c~Q
~ ~
~ 0
~ ~
rr- ."
o r
:f S;
o Z
~
m
I
,
.", ,-
5
.
Q,p;;:
~&3
0' .
~~~
., III Q
{ ),
3 2
0"
~ .
'f' g
;l1...V\b
Ef....Ct"
Q,"'::f11l
,/}!I'~R
"",,82:
~o.. ()
~?lQ
~ ti ... tJ1
g g.ooo ~
'<::Jc::r:1
W~ i ~
f}~Ol'f}">
-aa:
~[f~
Si
f
z
.~
f
u
o
p
f
g 00009
" w
'Ii:
o~;:om~
g ~.e. ~'<
<lI <II '" U
o.~:;:~
n -
~ ~
boDo'
- -<-I--- 05" (; >>
I '" '00 <to ~.
!J ~~!~
'" ~ ~ ~ ~
.."",..Jt*
....-1-0_
; 7: :ii
a g ~,I~I
:B' ~.
0"",:;
~ ~ ~'II
g3"tl
,,>CQ
1ft Xl N .
N ·
"N"
'" 0- ..
.. '"
00"
(J\NV.
M 101II1
o
. 0
gB
.:o~ ~
t;'
:i
[I
~
o
~
~
o
"
'"
.
Q
.'
'"
.
~
~
.
~
<
,
;
l
,
T
~
,
,
~.
;
,
,-
0:;;
~ ~
~r-
D ~
v,\- I
.c-J -1
o ~
}
. ~ ~_.
v
(J)
."
o
3
'"
01
....
....
)-
"
2,
~
<D
<D
<D
~<;i ->.
:i"w tJ":,
,~
!f2
,,3
.q
~~
.!l.
'11
..
~
.
..~c}
H
<z
. c
~3
~q
1I~
g !l.
-11
0-
~i
." 'iJ.
!
I
.'
11
~
~
~
.
i
"-
oil
.
~
.~
.
~
':::=-0
p~
"
..
.7
<T
'<
;;}
il
~
.
:-
:r
F
~
'"
~ ~~~[%g~
"3 a~~52~~
;::;" a. -a.il-... =
- _0.. 5-" D.
rl' ~~ ;tiO.S:l
~~[='tt:~~
i!!:lf!l:&g
ag&;t=go
~;:oa3:S!.i
. :g ~~ 5'
" Juh~"
'i~:r8ii
g.~o'!l.':i
:Jl3 . a.
~i~hg
iiI i.~ ~
_J"di
ii ..~H
~il~i'~i
rit!i
ih[~1
UdU
iiilh
.zO~.ii'
HH~i
iiHH
ii!~!i
~.I ~ ~l
~hhll
. il. o~
~ ~'ir"O g
o."""..!t.
~
'"
~
'"
~
N
-
~
~
~
o
<0
.'j""l>i..:.' I' .~, ,,"'l .' ""...,
'"
-..t 0) U\ .p.. <.>3 N
8:~~
g i:il s
g",q
n<'.j a
~i:~
~_li
. . ~
::~a.
:::;1>-[
~ n
~ ~
~
g"
gQg
dS
-~~
," 0 ~
~~[
::::;,g'g
~@>
8 E:
~ :;
~
5'
.
~~8g
""~~
-Ol\l:lti\
$D1<l'zj{ll
::~~~
~ ~~
8 t:lt-'
~ n>
o~
!j1;;!
~oo
o
~
f~lf~
tT~ =m
~ ~~~~
::~~=-.~
:::; i~~
- Q"'...j
~ 5!:g 0
~ ~~~
VI . g,c:
to"
eS~
~S~
~~trl
~
,
..0..0'" **
....a.N~
00 VI ..0 ~)
~F"" : c:>....,.c\l
~ i:4,~ ~ i\U
q ~ ~,cg, @\\Il
" ~g:B~'
g ~ ",t i
~: ~,',I,
(J\. f'to) VI\
'" _ 1
",
L
"'.-
!l-""~"" '-<lli!.~-"'-"'1.j
-
_ "u
~
,-
s-
.
!?.);>~
(J) 0.3
~ ~.
" . ~
0.."
~.a.
8
(f)6
~~
g:.
o~
n
Ii
~~
fr
....
~...
-...
~~
a:, Ia'.
$"
-0
, ~~
'<l::J
I~
D/~
~i
Q\
"
G
G
"
.
i
if
3
.'
I
.
.
G
~
o
~
~
.
" 0
:i: OOOOff
{ gfHi
a.....
" . 0
n
;r ~
. :Jooo'"
05"O;::JJ
~::!~~
oif 0;:053
-::r::l 0" ..
a>a:::Jpa.J:l
~.!~~ g
g' '2
)>':::J ;0
~e-i3 ~
i;p!. n Q
~~ ~
"'-c ell
. "
"
.
~
n
~.
.
<s-
e~
:ig.
"'~
8~
oil.
~
f--
:~
!}""
~!
<TO>
~f
~Q.
~
'"
00
~ ~.
- c
5" ~
. ~ a.
~
G
;:'0 ~Q ~ ~
It 0 tit - )l'
f-- !iQ-[.t
;II" ;=~"lt
It 0 0. 3i3
- a:li"
"'f1~ fi?6' g Glif
~_"',...~!!.Q,OI
o:i 8 :::;:
II (l) -. rt) "0 3 -
:o~~i"~'~
_@~ IIlSC
- :r;xl ;:to Q. s,to z..
.. 0 ~
."
"
;0
.
3
.
it
-~ ~""","""~",
GOLD13ECK MccAFFERTY & McKEEVER
, BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
III S. Independence Mall East
Philadelphia, P A 19106
215-627-1322
Attorney for Plaintiff
GE CAPITAL MORTGAGE SERVICES INe.
4680 Halhnark Parkway
San Barnardino, CA 92407
IN THE COURT OF COMMON PLEAS
Plaintiff
of Onnberland County
vs.
CNILACTION - LAW
TAMILLAA. MARTIN
OLLIE B. MARTIN, III Mortgagor(s) and
Record Owner( s)
ACTION OF MORTGAGE FORECLOSURE
6 Koser Road
Shippensburg, P A 17257
Term
No. OI-3763-Civil Term
Defendant( s)
SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129
GE CAPITAL MORTGAGE SERVICES INe., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck,
Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the
real property located at:
6 Koser Road
Shippensburg, P A 17257
LN ame and address of Owner( s) or Reputed Owner( s):
T AMILLA A. MARTIN
30 Oak Hill Road
Carlisle, PA 17013
OLLIE B. MARTIN, III
758 Shippensburg Road
Newville" PA 17241
2. Name and address of Defendant(s) in the judgment:
TAMILLA A. MARTIN
30 Oak Hill Road
Carlisle, PA 17013
OLLIE B. MARTIN, III
758 Shippensburg Road
Newville" PA 17241
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
P A DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
-~
,-
,
, i'~~~~'""i
, . P.O. Box 2675
Harrisburg, PA 17105-2675
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
Cumberland Co. Adult Probation
Courthouse Square
Carlisle, PA 17013-3387
BUREAU OF COMPLIANCE
Dept 280946
Harrisburg, PA 17128,0946
4. Name and address of the last recorded holder of every mortgage ofrecord:
Members First Federal Credit Union
5275 E. Trindle Road
Mechanicsburg, PA 17055
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by tite sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
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 tile sale.
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and conect to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn h11sification to authorities.
DATED: March 26,2002
~
GOLDBECK cCAFFERT & McKEEVER
BY: Joseph A. Goldbeck, Jr. Esq.
A ttomey for Plaintiff
,_._~,
,. ~
-<',
~'~<"
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND } SS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriffs Deed in which ecretarv of Housing & Urban Dev is the grantee the same having been sold
to said grantee on the 5th day of June A.D., 2002, under and by virtue of a writ Execution issued on the
11th day of Feb, A.D., 2002, out of the Court of Common Pleas of said County as of Civil Term, 02
Number 3763, at the suit ofGE Capital Mtg Serv Inc against Tamilla A Martin & Ollie B Martin III is
duly recorded in Sheriffs Deed Book No. 253, Page 1.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this L day of ~.D. 2W1-;
r
~ fb X.JAr, ~
Recorder of Deeds
~ '"~,,,..
-
-
"
hi'
GE Capital Mortgage Services Inc.
VS
Tmnilla A Martin and Ollie B.
Martin, III
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2001-3763 Civil Term
Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states
that on February 25,2002 at 2:55 o'clock pm, EST, he served a true copy ofthe within
Real Estate Writ, Notice and Description, in the above entitled action, upon the within
named defendant, to wit: Tamilla A Martin, by making known unto Tamilla A Martin
personally, at 758 Shippensburg Road, Newville, Cwnberland County, Pennsylvania, its
contents and at the same time handing to her personally the said true and correct copy of
the same.
Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states
that on February 25,2002 at 10:35 o'clock am, EST, he served a true copy of the within
Real Estate Writ, Notice and Description, in the above entitled action, upon the within
named defendant, to wit: Ollie B. Martin, III, by making known unto Tammy Frank,
adult girlfriend of defendant, at 405 Juniper Street, Carlisle, Cwnberland County,
Pennsylvania, its contents and at the same time handing to her personally the said true
and correct copy of the same.
Gerald Worthington, Deputy Sheriff, who being duly sworn according to law,
states that on April 5, 2002 at 4:00 o'clock P.M., E.S.T., he posted a true copy ofthe
within Real Estate Writ, Notice, Poster and Description, in the above entitled action,
upon the property of Tamilla A. Martin and Ollie B. Martin, III located at 6 Koser Road,
Shippensburg, Pennsylvania, according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law says he served
the above Real Estate Writ, Notice, Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action to one of the within named
defendants to wit: Tamilla A Martin, by regular mail to her last known address of 758
Shippensburg Road, Newville, P A 17241. This letter was mailed under the date of April
04, 2002 and never returned to the Sheriff's Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law says he served
the above Real Estate Writ, Notice, Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action to one of the within named
defendants to wit: Ollie B. Martin III, by regular mail to his last known address of 405
Juniper Street, Carlisle, PA 17013. This letter was mailed under the date of April 04,
2002 and never returned to the Sheriff s Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after
due and legal notice had been given according to law, exposed the within described
premises at public venue or outcry at the Court House, Carlisle, Cwnberland County,
Pennsylvania, on June 5' 2002 at 10:00 o'clock AM. He sold the same for the swn of
$1.00 to Secretary of Housing and Urban Development, his successors and assigns. It
being the highest bid and best price received for the same, Secretary of Housing and
Urban Development, his successors and assigns of 100 Penn Square East, 10th Floor,
Wanamaker Building, Philadelphia, P A 19106, being the buyer in this execution paid
SheriffR. Thomas Kline, the swn of $708.80, it being costs.
,~.~' .~
Sheriff s Costs:
Docketing
Poundage
Posting Bills
Advertising
Acknowledging Deed
Auctioneer
Law Library
Prothonotary
Service
Certified Mail
Levy
Surcharge
Legal Search
Law Journal
Patriot News
Share of Bills
Distribution of
Proceeds
Sheriffs Deed
,~
'>"'~;"
$30.00
13.90
15.00
15.00
30.00
10.00
1.00
24.15
4.50
15.00
30.00
246.80
193.75
25.20
25.00
29.50
$708.80 paid by attorney
07/23/02
Sworn and subscribed to before me
SOAn~, ~/-#
~ ~)p~.It:. ~
This .Lo ~day of (J" JuJ-" r '
g j R. Thomas Kline, Sheriff
2002, A.D. uf () ~itt!f7
Po onotary ~~
:eaIE;tat~t1>eputy
Jt.-~
30'tfO oJ-~
I uO '
, CA 37 V" '-I
flu /J..!1o<f
~,,,,.,- ~, ~,M"
,,,
~~ .~'- ~
~" ~
-k.,~",",... L
""'L --~; ",,:,,"'.h"'-",,-.,,~,~ ~'_
WRIT OF EXECUTION and/or ATTACHMENT
. ,
COMMONWEALTH OF PENNSYL VANIA)
COUNTY OF CUMBERLAND)
NO 01-3763 Civil
CIVIL ACTION -LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due GE CAPITAL MORTGAGE SERVICES INC
PLANTIFF(S)
From TAMILLA A MARTIN AND OLLIE B MARTIN III
(I ) You are directed to levy upon the property of the defendant( s) and to sell SEE LEGAL
DESCRIPTION OF PROPERTY
(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 notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account ofthe defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
gamishee and is enjoined as above stated.
Amount Due $72,155.10
L.L.
Interest FROM 9/11/01 TO SALE DATE AT $11.86 PER DIEM
Atty's Comm
%
Due Prothy $1.00
Other Costs
Atty Paid $776.33
Plaintiff Paid
Date: FEBRUARY 11, 2002
CURTIS R. LONG
Prothonotary, Civil Division
By:
<,(J~ )!.~, W
REQUESTING PARTY:
Name JosephA. Goldbeck, Jr. Esq.
Address: SillTE 500 - THE BOURSE BLDG 111 S. INDEPENDENCE MALL EAST
PHILADELPHIA, PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No. 16132
~tJ~L.'!.'~~'lh r,;:"Ji1t;J; '"",. H !_,'_; ~ """,~,~~",, ",~j,',;,-
". .', \~i;)T,,,,,j~'lj~;j\JI~it~if,*,~"''iilWt,,~!~~,j,Hqil;-;;~'k.-ii>ijk!k<lli,,,,"w$,"","!""",~'".U<<,j;.HI"i\.I"'-,';".i~~;@~~' ~ ~ - <~ ilf.d
. REAL ESTATE SALE No. L 3
On February 222002, the sherifflevied upon the
defendant's interest in the real property situated in
North Newton Township, Cumberland County, P A,
known and numbered as 6 Koser Roadi Shippensburg
and more fully described on Exhibit "A" filed
with this writ and by this reference incorporated herein.
Date: February 22,2002
By: J/lckt Sw"i~
Real Estate Deputy
~II
-:\
.,. \ ,~\\H3c\
>. '\;" ,f ,..,
\\,\ \j[ t, \ \ a1~
,. ,'," , ~~ ('\'J
.' ;~;1;:l:l()
}.,i,"i\\~ "" j\.i ,. '
:l:l\'U='" ..
~'''':i<iit,_ I
~
c::uiI
~
~'c:3
GV
(;iii
M
.~
~'"
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Frank J. Epler being duly sworn according to law, deposes and says:
That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the
City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News andJhg
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 continuousiy 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 April 2002 and the
7th day(s) of May 2002. 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 duiy 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 subsequentiy duly recorded in
the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317.
PUBLICATION
COPY
SALE #23
~~""""':"'~;;~"~~~'o""'~"""~;'~:~:"
---.-=='''-"=,<"'':"
. REAL ESTATE SALE No. 23
C Wrll No. 200t-3763
Civil Term
GE Capital Mortgage
Services Inc.
vs
Tamllla A. Martin and
.._. 01l1e B. Martin, 111
- Atty: Joseph Goldbeck
DESCFJPTIO!,!
,,"ALLJIIAT CERTAIN piece or parcel of land
si~~.yiN.9rt.h Newton TOW11Sbie, Cumberland
-County. :Pennsylvania, more particularly bonded
1llia descnlled as follows, to wit
.'" BEG@NINGata railroad spike in the center line
,~--=<!rTowi'jship Route 330 at comer oflands now or
.,_lQnn,'~,1 _,Of Dana L, . Peterson, ~t ux; thence by
~aJan:Gs of Petersoll., Sooth 42 ~orees OS
~-mm!lter30- seconds We~t, 231.32 feefto an iron
1!n,m-The property oflands now or formerly of
,-W. Harold Yohe; thence by said land:. of Yohe.
'-NorllL~ degrees 27 minutes 06 seconds West,
1J024 lee' ."'.,an od.'tiopom," f,,!" post; Publisher's Receipt for Advertising Cost
~thence::IDr same, North 41 degrees 15 mmutes26
:~~opds East, 199,35 fiet!o an .iron ~in;'~ence" publisher of The Patriot-News and The Sundav Patriot-News. newspapers of general
-OObtlnltiJlgby same, North 65 dogre" "6tnlD1ltes . t f th f 'd t' d bl' t' d .rt'f' th th h
~,-aLsemnQs.JYest, 26.19 feet to an iron pin at.e recelp 0 e a oresal no Ice an pu Ica Ion costs an ce lies at e same ave
t c:citn~ -of lands now or fonnerly of Norman I.
',""'Wesf;'lnence by said lands of West, North 42
de~s'05 minutes 30 seconds East, 92.55 feet to .
"'if ra!froad spike in the center line of .said
- Towp]}iip Route, Sooth 45 degrees 14 minutes 37
w:onds: East, 150 feet to a-railroad spike, the
place"ofBEGlNNlNG.
Tax Fakel #30.11.0306.007 A.
:Bmcrknown as 6 Koser Road, Shippensburg,
1',(17151: .
No~rlal Seal
Terry L. RUSS~Jf. NOlary pubnc
Harrisburg, Dauphin COUnly
My Commission expires June 6. 2002
Member, PennsylvanIa ASSOCIation ot Notarfes
NO"P RY PUBLIC
My commission expires June 6, 2002
-.J
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERlAND COUNTY COURTHOUSE
CARLISLE, PAc 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
$
$
$
192.00
1.75
193.75
By....................................................................
~ '
, J'
"
l!IJIIl h--.,;^
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. Morgeuthal, 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 ofthe said Cumberland Law
Journal on the following dates,
VIZ:
APRIL 26, MAY 3,10,2002
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.
SWORN TO AND SUBSCRIBED before me this
10 day of MAY. 2002
NOli
LOIS E. SNYDER, Notary PublIc
C.al'lisle Bore, Cumberfand County
My CornmlssIoIi ExpAs Man:h 5. 2005
~~~i~;~~',<ti;i;ibf~~'~!!l~~i4-fi,jJ1:j~>!;;;"'Jtll,;,'iW''';'''')'>;;",":c,,,;,,,",:,.""""",;;",!".t;~'""iL'b';4lj~':lO'
*'~mti!jij[ ,.~ ~c_,,,, ~bl!lliILml5ii1liil~ '
'-',1
Ii
:1
REAL ESTATE SALE NO. 23
Writ No. 2001-3763 Civil
GE Capital Mortgage Services Inc.
vs.
Tamilla A Martin and
Ollie B. Martin, III
Atty.: Joseph Goldbeck
ALL THAT CERTAIN piece or par-
cel of land situate in North Newton
Township, Cumberland County,
Pennsylvania, more particularly
bounded and described as follows.
to wit:
BEGINNING at a railroad spike
in the center line of Township Route
330 at corner of lands now or for-
merly of Dana L. Peterson et ux;
thence by said lands of Peterson,
South 42 degrees 05 minutes 30
seconds West. 231.32 feet to an iron
pin in the property of lands now or
fOl.merly of \V. Harold Yohe: thence
by said lands of Yohe, North 68 de-
grees 27 minutes 06 seconds West,
130.24 feet to an existing corner
fence post; thence by same, North
41 degrees 15 minutes 26 seconds
East. 199.35 feet to an iron pin;
thence continuing by same, North
65 degrees 26 minutes 00 seconds
West. 26.19 feet to an iron pin at
corner of lands now or formerly of
Norman I. West: thence by said
lands of West. North 42 degrees 05
minutes 30 seconds East, 92.55
feet to a railroad spike in the center
line of said Township Route, South
45 degrees 14 minutes 37 seconds
East. 150 feet to a railroad spike.
the place of BEGINNING.
Tax Parcel #30-11-0306-007 A.
Being known as 6 Koser Roact
Shlppensburg. PA 17257.
- ,
-,..
'~-"".~ ~., ~~_.^ =- " ,
J,
~
~~-",
j
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
GE CAPITAL MORTGAGE SERVICES INC.
4680 Hallmark Parkway
San Barnardino, CA 92407
Plaintiff
IN THE COURT OF COMMON PLEAS
of Cumberland County
Vs.
CIVIL ACTION - LAW
TAMILLA A. MARTIN
OLLIE B. MARTIN, III
(Mortgagors and Record owners)
6 Koser Road
Shippensburg, PA 17257
Defendants
ACTION OF MORTGAGE FORECLOSURE
Term No. 01-3763-civil Term
AFFIDAVIT PURSUANT TO RULE 3129
GE CAPITAL MORTGAGE SERVICES INC., Plaintiff in the above action, by its
attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe
for the writ of execution was filed the following information concerning the real
property located at:
6 Koser Road Shippensburg, PA 17257
1.Name and address of Owner(s) or Reputed Owner(s):
TAMILLA A. MARTIN
30 Oak Hill Road, Carlisle, PA 17013
OLLIE B. MARTIN, III
758 Shippensburg, Road Newville, , PA 17241
2. Name and address of Defendant(s) in the judgment:
TAMILLA A. MARTIN
30 Oak Hill Road, Carlisle, PA 17013
OLLIE B. MARTIN, III
758 Shippensburg Road, Newville, , PA 17241
. Name and last known address of every judgment creditor whose judgment is a record
lien on the property to be sold:
PA DEPARTMENT OF PUBLIC WELFARE -
Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320, Carlisle, PA 17013
Cumberland Co. Adult Probation
Courthouse Square, Carlisle, PA 17013-3387
,
c,
-., -'''''~..,~:;
,
.-
4. Name and address of the last recGrded'~older of every mortgage of record:
Members First Federal Credit Union
5275 E. Trindle Road, Mechanicsburg, PA 17055
5. Name and address of every other person who has any record interest in or record
lien on the property and whose interest may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who
has any record interest in the property which may be affected by the sale.
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.
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to
the best of my personal knowledge or information and belief. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. Section
4904 relating to unsworn falsification to authorities.
DATED: February 7, 2002
Jr. 1 Esq.
""',~~
'. J"
~Ii' ~ ,~, ~,c
\.. .r'
\,
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
III S. Independence Mall East
Philadelphia, P A 19106
215-627-1322
Attorney for Plaintiff
GE CAPITAL MORTGAGE SERVICES INC IN THE COURT OF COMMON PLEAS
4680 Hallmark Parkway
San Barnardino, CA 92407 of Cumberland County
Plaintiff
V s. CNIL ACTION - LAW
TAMILLA A. MARTIN ACTION OF MORTGAGE FORECLOSURE
OLLIE B. MARTIN, III
(Mortgagors and Record Owners) Term No. 01-3763-Civil Term
6 Koser Road
Shippensburg, P A 17257
Defendants
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: MARTIN. TAMILLAA.
TAMILLA A. MARTIN
30 Oak Hill Road
Carlisle, P A 17013
Your house at 6 Koser Road, Shippensburg, P A 17257 is scheduled to be sold at Sheriffs Sale on
Wednesday, June 05, 2002, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the
court judgment of$72,155.10 obtained by GE CAPITAL MORTGAGE SERVICES INC against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be cancelled if you pay to GE CAPlI AI. MORTGAGE SERVICES INC, the back
payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call:
215-627-1322
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
'-'" ~ '. '
.' ~
,"."""
\ ?'
You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriffof717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the
Sheriffs Sale. This schedule will state who will he receiving that money. The money will be paid out in
accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed
with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, P A 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
"'
= "
.~ -1:;_~~"",,'j>
GOLDBECK McCAFFERTY & McKEEVER
By: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
(215) 627-1322
ATTORNEY FOR PLAINTIFF
GE Capital Mortgage Services, Inc.
4680 Hallmark Parkway
San Bernardino, CA 92407
Vs.
Ollie B. Martin III
758 Shippensburg Road
Newville, PA 17241
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO 01-3763-Civi1 Term
Tamilla A. Martin
30 Oak Hill Road
Carlisle, PA 17013
ALL THAT CERTAIN piece or parcel of land situate in North Newton
Township, Cumberland County, Pennsylvania, more particularly
bonded and described as follows, to wit:
BEGINNING at a railroad spike in the center line of Township
Route 330 at corner of lands now or formerly of Dana L, Peterson
et ux; thence by said lands of Peterson, South 42 degrees 05
minutes 30 seconds West, 231.32 feet to an iron pin in the
property of lands now or formerly of W. Harold Yohe; thence by
said lands of Yohe, North 68 degrees 27 minutes 06 seconds West,
130.24 feet to an existing corner fence post; thence by same,
North 41 degrees 15 minutes 26 seconds East, 199.35 feet to an
iron pin; thence continuing by same, North 65 degrees 26 minutes
00 seconds West, 26,19 feet to an iron pin at corner of lands
now or formerly of Norman I. West; thence by said lands of West,
North 42 degrees 05 minutes 30 seconds East, 92.55 feet to a
railroad spike in the center line of said Township Route, South
45 degrees 14 minutes 37 seconds East, 150 feet to a railroad
spike, the place of BEGINNING.
Tax Parcel #30-11-0306-007A
Being known as 6 Koser Road, Shippensburg, PA 17257
. .
"
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suile 500 - The Bourse Bldg.
III S. Independence Mall East
Philadelphia, P A 19106
215-627-1322
Attorney for Plaintiff
GE CAPITAL MORTGAGE SERVICES INC. IN THE COURT OF COMMON PLEAS
4680 Hallmark Parkway
San Barnardino, CA 92407 of Cumberland County
Plaintiff
Vs. CIVIL ACTION - LAW
TAMILLA A. MARTIN ACTION OF MORTGAGE FORECLOSURE
OLLIE B. MARTIN, III
(Mortgagors and Record Owners) Term No. 01-3763-Civil Term
6 Koser Road
Shippensburg, P A 17257
Defendants
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: MARTiN, III, OLLIE 8.
OLLIE B. MARTIN, III
758 Sbippensburg Road
Newville" PA 17241
Your house at 6 Koser Road, Sbippensburg, P A 17257 is scheduled to be sold at Sberiffs Sale on
Wednesday, June 05, 2002, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courtbouse to enforce tbe
court judgment of$72,155.10 obtained by GE CAPITAL MORTGAGE SERVICES INC. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sberiffs Sale you must take immediate action:
1. The sale will be cancelled if you pay to GE CAPITAL MORTGAGE SERVICES INC., the back
payments, late charges, costs and reasonable attorney's fees due. To find out bow much you must pay call:
215-627-1322
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
'cUiil
~
'*'" ~
_M.' ~,...~.:"';
You may ueed an attorney to assert your rights. The soouer you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only ifthe buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of7l7-240-6390.
4. Ifthe amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as ifthe sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the
Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in
accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed
with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty A venue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
'.""
,
~~~''"~;'f'!
GOLDBECK McCAFFERTY & McKEEVER
By: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
(215) 627-1322
ATTORNEY FOR PLAINTIFF
GE Capital Mortgage Services, Inc,
4680 Hallmark Parkway
San Bernardino, CA 92407
Vs,
Ollie B, Martin III
758 Shippensburg Road
Newville, PA 17241
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO 01-3763-Civi1 Term
Tamilla A. Martin
30 Oak Hill Road
Carlisle, PA 17013
ALL THAT CERTAIN piece or parcel of land situate in North Newton
Township, Cumberland County, Pennsylvania, more particularly
bonded and described as follows, to wit:
BEGINNING at a railroad spike in the center line of Township
Route 330 at corner of lands now or formerly of Dana L. Peterson
et ux; thence by said lands of Peterson, South 42 degrees 05
minutes 30 seconds west, 231.32 feet to an iron pin in the
property of lands now or formerly of W. Harold Yohe; thence by
said lands of Yohe, North 68 degrees 27 minutes 06 seconds West,
130.24 feet to an existing corner fence post; thence by same,
North 41 degrees 15 minutes 26 seconds East, 199.35 feet to an
iron pin; thence continuing by same, North 65 degrees 26 minutes
00 seconds West, 26.19 feet to an iron pin at corner of lands
now or formerly of Norman I. West; thence by said lands of West,
North 42 degrees 05 minutes 30 seconds East, 92.55 feet to a
railroad spike in the center line of said Township Route, South
45 degrees 14 minutes 37 seconds East, 150 feet to a railroad
spike, the place of BEGINNING.
Tax Parcel #30-11-0306-007A
Being known as 6 Koser Road, Shippensburg, PA 17257