HomeMy WebLinkAbout01-03989A
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PR.AECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.RC.P.3180-3183
FIRST HORIZON HOME LOAN CORPORATION, CUMBERLAND COUNTY
F/K/A FT MORTGAGE COMPANIES, DB/A MNC
MORTGAGE Na.01-3989
Plaintiff,
v.
VALERIE L. XANNONE
GARY S.YANNONE
Defendant(s).
TO THE DIItECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due
$142,749.67 Y
Interest from 8/16/01 to 12/5/01
(per diem - $23.47)
TOTAL
Note: Please attach description of property.No.
$2,605.17 and Costs
$145,354.84
PENN CENTE~at SUBURBAN STATION
E 1400
ADELPHIA, P 19103
iev for Plaintiff
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ALL THAT CERTAIN piece or parcel of land with the buildings and improvements thereon
e~tected, if any, situate in Wentz Run Heights, North lvliddleton Township, Cumberland County,
Commonwealth of Pennsylvania bounded and described in accordance with Final Subdivision Plan
for Phase No. II for "Wertz Run Heights," recorded on October 16, 1996, in Cumberland County
Plan Book 73, Page 47, as follows, to wit:
BEGINNING at a point, said point being located on the Eastern right-of--way line of Graft Court at
the common front property corner of Lot #14 and Lot #13 of Wertz Run Heights, Phase 2; thence
along the Eastern right-of-way line of Grant Court North 37 degrees 15 minutes 00 seconds East, a
distance of 15.88 feet to a point; thence along the same on the arc of a curve, curving to the right
having a radius of 10.00 feet, an arc length of 17.45 feet and a central angle of 49 degrees .59
minutes 41 seconds [o a point; thence along the same on the arc of a curve, curving to the left
having a radius of 50.00 feet, an arc length of 122.17 feet and a central angle of 139 degrees 59
minutes 41 seconds to a point at Lot #12 of Wertz Run Heights, Phase 2; thence along Lot #12
North 37 degrees 15 minutes 00 seconds East, a distance of 105.00 feet to a point at Lot #1 of
Wertz Run Heights, Phase 2; thence along Lot #1 South 73 degrees 45 minutes 31 seconds East, a
distance of 255.33 feet to a point at land now or late of Kollas and Costopoulos, Kingsbrook Phase
VII; thence along a portion of land now or late of Kollas and Costopoulos, Kingsbrook Phase VII;
thence along a portion of land now or late of Kollas and Costopoulos, Kingsbrook Phase VII, land
now or late of John I., Lois G., and Betsy K. Taylor, land now or late of David J. and Sharon J.
Schaffer, land now or late of Steven L. and Tammy A. Fisher, and a portion of land now or late of _
Barry W. and Sandra E. Swope South 18 degrees 43 minutes 30 seconds West, a distance of 285.00
feet to a point at Lot #14 of Wertz Run Heights, Phase 2; thence alongLot #14 North 71 degrees 16
minutes 40 seconds West, a distance of 144.17 feet to a point; thence along the same North 52
degrees 45 minutes 00 seconds West, a distance of 167.23 feet to a point on the Eastern right-of-
way line of Grant Court, the point of Beginning.
SAID LOT CONTAINS 73,192.86 square feet or 1.680 acres.
BEING Lot #13 of the Final Subdivision Plan of Wertz Run Heights, Carlisle, Cumberland County,
Pennsylvania, recorded in Plan Book 73, Page 47, on October 16, 1996.
TAX PARCEL #29-OS-0429-034
TITLE TO SAID PREMISES IS VESTED IN Gary S. Yannone and Valerie L. Yannone, his wife
by Deed from Kollas and Costopoulos, a PA General Partnership comprised of William C. Kollas
and William C. Costopoulos dated 6/11/98 and recorded 6116/98 in Record Book 179 Page 283.
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FIRST HORIZON HOME LOAN CORPORATION,
F/K/A FT MORTGAGE COMPANIES, DB/A MNC
MORTGAGE
v.
Plaintiff,
VALERIE L. YANNONE
GARY S.YANNONE
Defendant(s).
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO.O1-3989
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. l)
FIRST HORIZON HOME LOAN CORPORATION, F/K/A FT MORTGAGE COMPANIES,
DB/A MNC MORTGAGE, Plaintiff in the above action, by its attorney, FRANK FEDERMAN,
ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following
information concerning the real property located at LOT #13, GRANT COURT WERTZ RUN
HEIGHTS, CARLISLE, PA 17013
Name and address of Owner(s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
VALERIE L. 1002 WEST FOXCROFT DRIVE
YANNONE CAMP HILL, PA 17011
1555 MCCLURES GAP ROAD
GARY S. YANNONE CARLISLE, PA 17013
2. Name and address of Defendant(s) in the judgment:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Same as above
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
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4. Name and address of the last recorded holder of every mortgage of record:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
Name and address of every other person who has any record lien on the property:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
6. Name and address of every other person who has any record interest in the property and whose
interest maybe affected by the sale:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
Name and address of every other person whom the plaintiff has knowledge who has any interest
in the property, which maybe affected by the sale:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Tenant/Occupant LOT #13, GRANT COURT WERTZ RUN
HEIGHTS
CARLISLE, PA 17013
Domestic Relations of Cumberland 13 North Hanover Street
County Carlisle, PA 17013
Commonwealth of Pennsylvania p0 Box 2675
Department of Welfare
Harrisburg, PA 17105
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. Sec. 4904 relating tc
AUQUSt 28.2001
DATE
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FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Suite 1400
One Penn Center at Suburban Station
Philadelphia, PA 19103
(215)563-7000
FIRST HORIZON HOME LOAN CORPORATION,
F/K/A FT MORTGAGE COMPANIES, DB/A MNC
MORTGAGE
Plaintiff,
v.
VALERIE L. YANNONE
GARY S.YANNONE
Defendant(s).
ATTORNEY FOR PLAINTIFF
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO.Ol-3989
CERTIFICATION
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in
the above-captioned matter, and that the premises are not subject to the provisions of Act 91
because it is:
() an FHA mortgage
O non-owner occupied
O vacant
(X) Act 91 procedures have been fulfilled
This certification is made subject to the penalties of 18 Pa. C:S. Section 4904 relating to unsworn
falsification to authorities.
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FIItST HORIZON HOME LOAN CORPORATION,
F/K/A FT MORTGAGE COMPANIES, D/B/A MNC
MORTGAGE
Plaintiff,
v.
VALERIE L. YANNONE
GARYS.YANNONE
befendant(s).
TO: VALERIE L. YANNONE
1002 WEST FOXCROFT DRIVE
CAMP HILL, PA 1701,1
August 29, 2001
CUMBERLAND COUNTY
No. 01-3989
GARY S. YANNONE
1555 MCCLURES GAP ROAD
CARLISLE, PA 17013
**THIS FIl2M IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WII,L B$ USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A pISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIItMED, 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 LOT #13, GRANT COURT WERTZ RUN HEIGHTS,
CARLISLE, PA 17013 is scheduled to be sold at the Sheriffs Sale on DECEMBER 5, 2001 at 10:00
a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the
court judgment obtained by FIRST HORIZON HOME LOAN CORPORATION. F/K/A FT
MORTGAGE COMPANIES, DB/A MNC MORTGAGE (the mortgagee) against you. If the
Sheriff's sale is postponed, the property will be relisted for the MARCH 6, 2002 Sheriff s Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payments; late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
call: (215) 563-7000.
2. You maybe 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.
You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling (2151563-7000.
2. You maybe able to petition the Court to set aside the sale if the bid price was grossly
inadequate compazed to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To
fmd out if this has happened, you may call (717) 240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you.
6. You maybe entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after the distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OITT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
~' (800) 990-9108
i 4
ALL THAT CERTAIN piece or parcel of land with the buildings and improvements thereon
9rected, if any, situate in Wentz Run Heights, North Middleton Township, Cumberland County,
Commonwealth of Pennsylvania bounded and described in accordance with Final Subdivision Plan
for Phase No. II for "Wertz Run Heights," recorded on October 16, 1996, in Cumberland County
Plan Book 73, Page 47, as follows, to wit:
BEGINNING at a point, said point being located on the Eastern right-of-way line of Gra~.t Coun at
the common front property corner of Lot #14 and Lot #13 of Wertz Run Heights, Phase 2; thence
along the Eastern right-of--way line of Grant Coutt North 37 degrees 15 minutes 00 seconds East, a
distance of 15.88 feet to a point thence along the same on the arc of a curve, curving to the right
having a radius of 10.00 feet, an arc length of 17.45 feet and a central angle of 49 degrees,59
minutes 41 seconds to a point; thence along the same on the arc of a curve, curving to the left
having a radius of 50.00 feet, an arc length of 122.17 feet and a central angle of 139 degrees 59
minutes 41 seconds to a point at Lot #12 of Wertz Run Heights, Phase 2; thence along Lot #12
Notch 37 degrees IS minutes 00 seconds East, a distance of 105.00 feet to a point at Lot #1 of
Wertz Run Heights, Phase 2; thence along Lot #1 South 73 degrees 45 minutes 31 seconds East, a
distance of 255.33 feet to a point at land now or late of Kollas and Costopoulos, Kingsbrook Phase
VII; thence along a portion of land now or late of Kollas and Costopoulos, Kingsbrook Phase VII;
thence along a portion of land now or late of Kollas and Costopoulos, Kingsbrook Phase VII, land
now or late of John I., Lois G., and Betsy K. Taylor, land now or lace of David J. and Sharon J.
Schaffer, land now or late of Steven L. and Tammy A. Fisher, and a portion of land now or late of _
Barry W. and Sandra E. Swope South 18 degrees 43 minutes 30 seconds West, a distance of 285.00
feet to a point at Lot #14 of Wertz Run Heights, Phase 2; thence alongLot #14 North 71 de,ees 16
minutes 40 seconds West, a distance of 1=4=1.17 feet to a point; thence along the same North 52
degrees 45 minutes 00 seconds West, a distance of 167.23 feet to a point on the Eastern right-of-
way line of Grant Court, the point of Begittning.
SAID LOT CONTAINS 73,192.86 squaze feet or 1.680 acres.
BEING Lot #13 of the Final Subdivision Plan of Wertz Run Heights, Carlisle, Cumberland County,
Pennsylvania, recorded in Plan Book 73, Page 47, on October 16, 1996.
TAX PARC~I. #29-OS-0429-034
TITLE TO SAID PREMISES IS VESTED IN Gary S. Yannone and Valerie L. Yannone, his wife
by Deed from Kollas and Costopoulos, a PA General Partnership comprised of William C. KolIas
and William C. Costopoulos dated 6/11/98 and recorded 6/16/98 in Record Book 179 Page 283.
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FEDERMAN AND PHELAN, LLP
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BOULEVARD
SUITE 1400
PHILADELPHIA, PA 19103-1814
(2151 563-7000
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
FIRST HORIZON HOME LOAN CORPORATION,
F/K/A FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE
4000 HORIZON WAY
IRVING, TX 75063
TERM
v.
Plaintiff
NO. O I' ~~ Cl J c.(,
VALERIE L. YANNONE
GARY S.YANNONE
LOT #13 GRANT COURT WERTZ RUN HEIGHTS
CARLISLE, PA 17013
Defendant(s)
CUMBERLAND COUNTY
CIVII. ACTION -LAW
COMPLAINT IN MORTGAGE FORECLOSURE
NOTICE
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WII.L BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY
RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIIIMED, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT
A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
You have been sued in Court. If you wish to defend against the claims set forth in the following
pages, you must take action within twenty (20) days after this Complaint and Notice aze served,
by entering a written appeazance 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.
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717)249-3166
Loan #: 0009299553
IF TffiS IS THE FIItST NOTICE THAT YOU HAVE
RECEIVED FROM THIS OFFICE, BE ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION
PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977),
DEFENDANT(S) MAY DISPUTE THE VALH)ITY OF
THE DEBT OR ANY PORTION THEREOF. IF
DEFENDANT(S) DO SO IN WRITING WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS
PLEADING, COUNSEL FOR PLAINTIFF WILL
OBTAIN AND PROVIDE DEFENDANT(S) WITH
WRITTEN VERIFICATION THEREOF;
OTHERWISE, THE DEBT WILL BE ASSUMED TO
BE VALID. LIKEWISE, IF REQUESTED WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS
PLEADING, COUNSEL FOR PLAINTIFF WILL
SEND DEFENDANT(S) THE NAME AND ADDRESS
OF THE ORIGINAL CREDITOR, IF DIFFERENT
FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT
UNTIL THE END OF THE THH2TY (30) DAY
PERIOD FOLLOWING FIRST CONTACT WITH
YOU BEFORE SUING YOU TO COLLECT THIS
DEBT. EVEN THOUGH THE LAW PROVH)ES
THAT YOUR ANSWER TO THIS COMPLAINT IS
TO BE FILED IN THIS ACTION WITHIN TWENTY
(20) DAYS, YOU MAY OBTAIN AN EXTENSION OF
THAT TIME. FURTHERMORE, NO REQUEST
WILL BE MADE TO THE COURT FOR A
JUDGMENT UNTIL THE EXPIRATION OF THIRTY
(30) DAYS AFTER YOU HAVE RECEIVED THI5
COMPLAINT. HOWEVER, IF YOU REQUEST
PROOF OF THE DEBT OR THE NAME AND
ADDRESS OF THE ORIGINAL CREDITOR WITHIN
THE THIRTY (30) DAY PERIOD THAT BEGINS
UPON YOUR RECEIPT OF THIS COMPLAINT,
THE LAW REQUH2ES US TO CEASE OUR
EFFORTS (THROUGH LITIGATION OR
OTHERWISE) TO COLLECT THE DEBT UNTIL
WE MAIL THE REQUESTED INFORMATION TO
YOU. YOU SHOULD CONSULT AN ATTORNEY
FOR ADVICE CONCERNING YOUR RIGHTS AND
OBLIGATIONS IN THIS SUIT.
Plaintiff is
FIRST HORIZON HOME LOAN CORPORATION,
F/K/A FT MORTGAGE COMPANgES, D/B/A MNC MORTGAGE
4000 HORIZON WAY
IItVIIQG, TX 75063
2. The name(s) and last known address(es) of the Defendant(s) are:
VALERIE L. YANNONE
GARY S.YANNONE
LOT #13 GRANT COURT WERTZ RUN HEIGHTS
CARLISLE, PA 17013
who is/are the mortgagor(s) and real owner(s) of the property hereinafter described.
3. On 6/11/98 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the
Recorder of CUMBERLAND County, in Mortgage Book No. 1460, Page 931.
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 10/1/00 and each month thereafter are due and unpaid, and by the terms of
said mortgage, upon failure of mortgagor to make such payments after a date specified by
written notice sent to Mortgagor, the entire principal balance and all interest due thereon
are collectible forthwith. A copy of such notice is attached as Exhibit "A."
6.
The following amounts are due on the mortgage:
Principal Balance $124,866.89
Interest 6,891.10
9/1/00 through 6/1/01
(Per Diem $25.15)
Attorney's Fees 4,000.00
Cumulative Late Charges 349.96
6/11/96 to 6/1/01
Cost of Suit and Title Seazch 550.00
Subtotal $136,657.95
Escrow
Credit 0.00
Deficit 4,155.17
Subtotal 4 155.17
TOTAL $140,813.12
8.
The attorney's fees set forth above aze inconformity with the Mortgage documents and
Pennsylvania Law, and will be collected in the event of a third party purchaser at
Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees
will be charged.
This action does not come under Act 6 of 1974 because the original mortgage amount
exceeds $50,000.00.
9. The Combined Notice has been sent to the Defendant(s) by regulaz and certified mail as
required by 35 P.S. § 1680.403c on the date(s) set forth in the true and correct copy of
such notice(s) attached hereto as Exhibit "A."
10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance
Program, Act 91 of 1983, has terminated because either:
(i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit
Counseling Agency in accordance with Plaintiff s written Notice to Defendants,
a true and correct copy of which is attached hereto as Exhibit "A"; or
(ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania
Housing Finance Agency.
WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of
$140,813.12, together with interest from 6/1/01 at the rate of $25.15 per diem to the date of
Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and
sale of the mortgaged property.
~,~.-!c~
/s/ Frank Federman
FRANK FEDERMAN, ESQUIItE
Attorney for Plaintiff
First Horizon Home Loan
4000 Horizon Way
Irving, TX 75063
VALARIE L. YANNONE
LOT #13 GRANT C
CARLISLE PA. 17013
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
LA NOTIICACION EN ED7UNT0 ES DE SUMA IMPORTANCIA, PUSS AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION IMMEDITAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVIAN HOUSING FINANCE AGENCY) SIN CARGOS AL NUMBERO
MENCIONADO ARRiBA. PUEDES SER ELEGIBLE PARR UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
+i~dfl~6~
This Notice contains important legal information. Tf you have any questions; representatives at the
Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an
attorney in your area. The local bar association maybe able to help you fmd a lawyer.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM IHEMAP) maybe able to help to save
your home. This notice explains how the oroeram works.
First Horizon Home Loan
4000 Horizon Way
Irving, TX 75063
GARY S.YANNONE
LOT #13 GRANT C
CARLISLE PA. 17013
ACT 91 NOTICE
TAKE ACTIOloT TO SAVE YOUR
HOME FROM FORECLOSURE
LA NOTIICACION EN EDJi1NT0 ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION IMMEDITAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVIAN HOUSING FINANCE AGENCY) SIN CARGOS AL NUMBERO
MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARR UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
i~l`~
This Notice contains important legal information. If you have any questions, representatives at the
Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an
attorney in your azea. The local bar association may be able to help you Find a lawyer.
First Horizon Home Loan
4000 Horizon Way
Irving, TX 75063
VALARB: L YANNONE
1555 MCCLURES CAP RD.
CARLISLE PA. 17013
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This Notice contains important legal information. If you have any questions, representatives at the
Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an
attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIICACION EN EDNNTO ES DE SUMA IMPORTANCIA, PUES APECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION IMMEDITAMENTE LLAMANDO ESTA
AGENCIA {PENNSYLVIAN HOUSING FINANCE AGENCY) SIN CARGOS AL NUMBERO
MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
-n~~ .
First Horizon Home Loan
4000 Horizon Way
Irving, TX 75063
GARY S.YANNONE
1555 MCCLURES CAP RD.
CARLISLE PA. 17013
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
To see if HEMAP can help you must MEET WITH A CONSUMER CREDIT COUNSELING
AGENCYWITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with you when you
meet with the Counseline Aeencv.
LA NOTIICACION EN ED7UNT0 ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION IMMEDITAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVIAN HOUSING FINANCE AGENCY) SIN CARGOS AL NUMBERO
MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARR UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
9. ~ Q
This Notice contains important legal information. If you have any questions, representatives at the
Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an
attorney in your area. The local bar association may be able to help you find a lawyer.
VALARIE L YANNONE
LOT # GRANT C
CARLISLE PA. 170li
0009299553
Orignta] Lender: FT. MORTGAGE COMP.
Current Lender: FIILST HORIZON CORP.
HOWEOWNER'S EMERGENCX MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME
FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR
EMERGENCY MORTGAEG ASSISTANCE:
*IF YOUR DEFAULT HAS BEEN CAUSED BY CIlZCUMSTANCES BEYOND YOUR
CONTROL,
*IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAE
PAYMENTS,AND
xIF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE-Under the Act, you aze entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must
arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at
the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. 1F YOL
CONSUMER CREDIT COUNSELING AGENCIES-Ifyou meet with one of the consumer credit
counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty
(30} days after the date of this meeting. The names, addresses and telephone numbers of desi¢nated
of this Notice. Tt is only necessary to schedule one face-to-face meeting. Advise your ]ender immediately of
your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE-Your mortgage is in default for the reasons set
forth later in this Notice (see following pages for specific information about the nature of your default). I
you have tried and aze unable to resolve this problem with the lender, you have the right to apply for
financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must
fill out, sign and file a completed a completed Homeowner's Emergency Mortgage Assistance Program
Application with one of the designated consumer credit counseling agencies listed at the end of this Notice.
Only consumer credit counseling agencies have applications for the program and they will assist you in
submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST
be filed or posmearked within thirty (30) days of your face-to-face meeting. -
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR i_ YOU
DO NOT FOLLOW THE OTHER TIME PERIODS ET FORTH IN THIS LETTER,
FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
i-I~®d~ .
AGENCY ACTION- Availab]e funds for emergency mortgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision after it receives your application. During that time,
no foreclosure proceedings wi]] be pursued against you if you have met the time requirements set forth
above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your
application.
NOTE: IF YOU ARE CURRENTLY PROTECTED SX THE FILING OF A PETITION IN
BANKRUPTCX, THE FOLLOWING PART OF THYS NOTICE YS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TOCOLLECT
THE DEST.
(If you bave filed bankruptcy you can still apply for Emergency Mortgage Assistance).
HOW TO CURE YOUR MORTGAGE DEFAULT Brin¢ it up to date).
NATURE OF THE DEFAULT- The MORTGAGE debt held by the above lender on your property
located at: - _.
LOT # 3 GRANT C -
CARLISLE PA. I7013
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts aze now past due:
Due = 70!0]!00 THRU 04/01/01 = 9416.68
Late Charges = $ 262.50
Other chazges (explain itemize):
Bad Check Fee = $
Other Fees = $ 43.75
Minus Suspense = $
TOTAL AMOUNT PAST DUE: $ 9416.68
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable):
HOW TO CURE THE DEFAULT-You may cure the default within THIRTY (30) days of the date of
this notice SY PAYNG THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS
$ 9416.68 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURING THE (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified
check or money order made payable and sent to:
First Horizon Hame Loan
4000 Horizon Way
Irving, TX 75063
Attn: Cashiering
You can cure any other default by inking the following action within THIRTY (30) DAYS of the date of
Yhis letter: (Do not use if no[ applicable,)
IF YOU DO NOT CURE THE DEFAULT-If you do not cove the default within THIRTY (30) DAYS of
the date of this Notice, the lenderintends to exercise its ri¢hts to accelerate the maH¢age debt. This
means that the entire outstanding balance of this debt will be considered due immediately and you may lose
the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not
made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to
foreclose uaon vour mortgaged arooerty.
IF THE MORTGAGE 7S FORECLOSED UPON-The mortgaged property will be sold by the Sheriff to
pay off the mortgage debt. If the ]ender refers your case to it's attorneys, but you cure the delinquency
before the lender begins legal proceedings against you, you will still be requued to pay the reasonable
attomey's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against
you, you will have to pay all reasonable attorney's fees actually incurred by the tender even if they exceed
$50.00. Any attomey's fees will be added to the amount you owe the lender, which may also include other
reasonable costs. If you cwe the default within the THIRTY (301 DAY oeriod, you will not be required to
pay attorney's fees.
OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance
and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-If you have not coved the default
within the THIRTY (30) DAY period aid forecloswe proceedings have begun, you still have the right to
in writine by the lender and by oerforming env other reouirements under the mortgage. Curing your
default in the manner set forth in this notice will restore your mortgage to the same position as if you
had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE-It is estimated that the eazliest date that such a
Sheriff s Sale of the mortgaged property could beheld would be approximately _9_months from the
date of this Notice, A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of
cowse, the amount needed to cure the default will increase the longer you wait. You may find out at any
time exactly what the requued payment or action will be by contacting the ]ender.
HOW TO CONTACT THE LENDER:
F'ust Horizon Home Loan
4000 Horizon Way
Irving, TX 75063
Atm: Loan Counseling Dept.
1-800-707-9998/Phone
1-214-441-7396/Fax
EFFECT OF SHERIFF'S SALE- You should realize that a Sheriffls Sale will end your ownership ofthe
mortgaged property and yaw right to occupy it. If you continue to live in the property after the Sheriff's
Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at
anytime.
ASSUMPTION OF MORTGAGE-You may or may not (CHECK ONE) sell or transfer your
home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding
payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other
requirements of the mortgage aze satisfied.
~117~ i
YOU MAY ALSO HAVE THE RIGHT
*TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THEMORTGAE DEBT OR TO
BORROWER MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
*TO HAVE THIS DEFAULT CURED BY ANY THIRT PARTY ACTING ON YOUR BEHLF.
*TO HAVE THEMORTGAGE RESTORED TO THE SAME POSITOIN AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER YOU DO NOT HAVE THIS RIGHT TO
CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
*TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOUSRE PROCEEDING OR
ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
*TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY
THE LENDER.
*TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
SINCERELY,
MALENDA TARGETT
DEFAULT REFERRAL SPECIALIST
Cc -62I2- TKY
P
PENNSYLVANIA HOUSING FINANCE AGENCY
HOMEOWNER'S EMERGENCY ASSISTANCE PROGRAM
CONSUMER CREDIT COUNSELING AGENCIES
(REV.8/00)
CLINTON COUNTY
Lycoming-Clinton Counties Commision for CCCS ofNortheaztem PA
Community Action (STEP) 1631 South Atherton SL, Suite 100
2138 Lincoln Street P.O. Box 1328 State College, PA 16801
Williamsport, PA 17703 (814) 238-3668 FAX (814) 238-3669
(570) 326-0587 FAX (570) 322-2197
CCCS ofNortheaztem PA
201 Basin SVeet
Williamsport, PA 17703
(570) 323-6627 FAX (570) 323-6626
31 ~ W. Market Street -
POB 1127 -
Wilkes-Barre, PA 18702
(570)821-0837 or (800)922-9537
FAX (570) 821-1785
Commission on Economics Opportunity of Luzeme County
163 Amber Lane
Wilkes-Barre, PA 18702
(570) 826-0510 or (800)822-0359
FAX (570) 829-1665-(Call Before Faxing)
(570) 455.4994 Haultown
FAX (570) 455-5631~Call Before Faxing)
(570) 836-0090 Tunkhannock
Booker T. Washington Center
1720 Holland Center
Erie, PA 16503
(814) 453-5744 FAX (814) 5749
John F. Kennedy Center, Inc.
2021 East 20'" Street
Erie, PA 16510
(814) 898-0400
FAX (814) 898-L243
CCCS of Western Pennsylvania, Inc.
2000 Linglesmwn Road
Harrisburg, PA 17102
(717)541-1757
Urban League of Metropolitan Harrisburg
N. 6'° Stmt
Harrisburg, PA 17101
(717) 234-5925 FAX (717) 234-9459
Community Action Comm of the Capital Region
1514 Deny Street
Hartisburg, PA 17104
(717) 232-9757 FAX (717) 234-2227
CUMBERLAW COUNTY
1400 Abington Executive Park
Suite I - . - -
Clarks-Summit. PA 18411
(570)587-9163 or (800) 922.9537
FAX (570) 587-9134-9131
Greater Erie Community Action Committee
l8 West 91h Svee[
Etie, PA 16301
(814) 459-4581 FAX (814) 456-0161
Shenango Valley Urban League, inc.
601 Indiana Avenue
Farrell, PA 16121
(412)981-5310
Financial Counseling Services of Franklin
31 West 3i° Street
Waynesboro, PA 17268
(717) 7623285
YWCA of Carlisle
301 "G"Street
Carlisle, PA 17013
(717) 243-3818 FAX (717) 731-9589
Adams Counry Housing Authority
139-143 Carlisle St.
Gettysburg, PA 17325
(717) 334-1518 FAX 334-8326
PENNSYLVANIA BULLETIN, VOL. 29, N0.23, JUNE 5, 1999
~, ~t~~~
ALL TBAT CERTAIN piece oe puoel of land with buildings and improvements thereon
erected, if say, simata In Wertz Atnt Iieigbta, NurW'MiddletmTowttddy, Cumbalsud Cormty,
Cottttnonwealth ofPenOSylvatiiahounded and destatbed iu aoeotdance tvit4 Piosl Subtlivisiou Plan
Gr Phaaa No. II for "Warn Itm Heights,":etorded as f3chther 15,1998, is Cnmberltud Cowry
Plan Book 73, Pager 47, as foilowa, to wit:
HEGINNII4G at a paiut, said point being located oa the eastern tight•of--way line of
Grant Court nt the common front property come oflgt q14 and Lot #13 of Wertz Run lirights,
phase 2; Thence along-the eastern slghbot~way 8ne of t3raat Court Nunh 37 degrees 1S winutes
0o xeonds Fart, a diatantx of 15.88 feat to a point; Thaaoe along the aamb oa the arc uf'a t7trve,
CULVing t0 ihC tight hiving a radius of 10.00 feKr an era length of 17.45 Gat and a central angle of
49 degrees 49 >mntues 41 seconds to a point; thence along the acme on the arc of a awe, caning
to tha k8 having a callus of So.00 feet, as ace length of 122.17 feet and a ceolral angle of 139
tlt:grees 39 miautee 41 zeaonds to apomt aE Lot plt2 of Wertz Run HtdghtR Phase Z•, thaucc along
Lot #12 North 37 degrees 1 S miwtu 00 aecottda East, a tfutaace of 103.00 foal to a point at Lut
#1 of W ertz Rua Heights, Phase 2; thence along let #13outh 73 degtces 45 whtutas 31 seconds
Fast, s diatmce of255.33 Ceet to a point el land now or htu ofIGoUas and Cos[opotdos,
IGngabroek Phase VII; thence nioag a partton oftaod uuw ur late of tcollas wd Coetnpoaloe,
ICiagshrook Phase VII, land sow or late of John I., Lois G., and Detsy K Tayltir, lead now ur fate
ufAavid 7. and Sharon 7.5ehaAar, lead now or tats of Steven L. awl Tammy A. Fiahcr, nod a
porQon ofland sow oz htte of Bury W. and Seadza B. Swope South 18 degrees 43 minutes 30
seeoads W set, s diRaacs of285:00 Get to a polar at Lot #14 of Wertz Run Flaights, YJuse 2;
thence along Lot #14 North71 degrees lb minutes 40 Seeonda West, a distance of 144.17 Feet to
a paint; tbeaee along the aama North 52 degrees 45 minutes 00 seconds West, a distance of
167.23 feat to a point oa the eastrta tight•ofway line of Gant Court, the point of BEGINNING.
SAII) LOT CONTAIN5 7;J 92.8G square feet or 1.680 acres. '
BEIIVG Lot A 13 ot'Ute Nlaai 5ubdivislon Plan of Wariz Run Fieigbu, Gulisla
Cumberhmd Cormty, Penarylvauia, morded'm Plan Book 73, Pager 47, ou Ociober i6, 1996,
68INC the name premises rhieh Kollar and Costopouloa, a~Pennsylvania
General Partnership. by 1te deed dated June 1996 end about to ba
recorded heravith.in she OfFica of the Recorder of Deeds of Cumberland
County, Peanaylvania, granted and conveyed unto Gasy S. Pannone and Valerie L.
Yanaone, hie viFe, MortgaROre herein.
PREMISES: LOT #13 GRANT C017RT WERTZ RHN HEIGHTS
VERIFICATION
RICHARD MINOR hereby states that he is ASSISTANT V.P. of FIIZST HORIZON
HOME LOANS CORPORATION mortgage servicing agent for Plaintiff in this matter, that he is
authorized to take this Verificafion, grid that the statements made in the foregoing Civil' Action in Mortgage
Foreclosure aze true and correct to the best of his knowledge, information and belief. The undersigned
understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom
falsification to authorities.
// ASSISTANT VICE PRESIDENT
DATE: b /aa~~l
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FEDERMAN AND PHELAN
By: FRANK FEDERMAN
Identification No. 12248
One Penn Center at Suburban Station
Suite 1400
Philadelphia, PA 19103-1814
(2151 563-7000
FIRST HORIZON HOME LOAN
CORPORATION, F/K/A FT MORTGAGE
COMPANIES, DB/A MNC MORTGAGE
4000 HORIZON WAY
IRVING, TX 75063
Plaintiff
Attorney for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
vs.
VALERIE L. YANNONE
1002 WEST FOXCROFT DRIVE
CAMP HILL, PA 17011
GARYS.YANNONE
1555 MCCLURES GAP ROAD
CARLISLE, PA 17013
Defendant(s)
NO. 01-3989
PRAECIPE FOR NDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment, in rem, in favor of the Plaintiff and against VALERIE L.
YANNONE and GARY S. YANNONE, Defendant(s), for failure to file an Answer to Plaintiffs
Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged
premises, and assess Plaintiffs damages as follows:
As set forth in Complaint $140,813.12
Interest 6/1/01 TO 8/16/01 $1,936.55
TOTAL $142,749.67
I hereby certify that (I) the addresses of the Plaintiff and Defendant(s) are as shown above,
and (2) notice has been given in accordance with Rule 237.1, copy attached.
~~,~ ~ dI~ d~`--
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED.
DATE: ao aoo~
isi ~' .P.
PROP THY/~~
**THIS F1RM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WII,L BE
USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS
NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT
A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
SHERIFF'S RETURN - REGULAR
CASE NO: 2001-03989 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FIRST HORIZON HOME LOAN COE2P
VS
YANNONE VALERIE L ET AL
KATHY CLARKE
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT-FORE was served upon
YANNONE VALERIE L the
DEFENDANT at 1416:00 HOURS, on the 13th day of July 2001
at 1002 W FOXCROFT DR
CAMP HILL, PA 17011 by handing to
THOMAS BALDWIN, FATHER
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing His attention to the contents thereof.
Sheriffs Costs: So Answers:
Docketing
Service 18.00
9.10
Affidavit .00
Surcharge 10.00 R. Thomas Kline
.00
37.10 07/16/2001
FEDERMAN & PHELAN
Sworn and Subscribed to before By:
me this day of Deput heriff
A.D.
Prothonotary
~;
CASE N0: 2001-03989 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FIRST HORIZON HOME LOAN CORP
VS
YANNONE VALERIE L ET AL
WARD
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
YANNONE GARY S the
DEFENDANT at 2038:00 HOURS, on the 12th day of July 2001
at 1555 MCCLURES GAP RD
SLE, PA 17013
by handing to
GARY S YANNONE
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 _6.00
Service 3.25
Affidavit .00
Surcharge 10.00
.00
19.25
Sworn and Subscribed to before
me this day of
A.D.
So Answers:
R. Thomas Kline
07/16f2001
FEDERMAN & PHELAN
De~y SSheriff~
Prothonotary
FEDERMAN AND PHELAN, L.L.P.
Frank Federman, Esquire
Identification No. 12248
One Penn Center Plaza at
Suburban Station, Suite 1400
Philadelphia, PA 19103-1799
(215) 563-7000
FIRST HORIZON HOME LOAN
CORPORATION, F/K/A FT MORTGAGE
COMPANIES, D/B/A MNC MORTGAGE
Plaintiff
vs.
VALERIE L. YANNONE
GARY S. YANNONE
Defendant(s)
TO: VALERIE L. YANNONE
1002 WEST FOXCROFT DRIVE
CAMP HILL, PA 17011
DATE OF NOTICE: AUGUST 3. 2001
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO. 01-3989
THIS FIRM IS A DEBT COLL TTEMPTING TO COLLECT A DEBT.
THIS NOTICE IS SENT TO Y TTEMPT TO COLLECT THE
INDEBTEDNESS REFERRED TO H I ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THAT E. IF YOU HAVE
PREVIOUSLY RECEIVED A DISCHARGE IN ANKRUPTCY, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN
AGAINST PROPERTY.
IMPORTANT NOTICE
You are in default because you have failed enter a written
appearance personally or by attorney and file in writing with the
court your defenses or objections to the claims set forth against
you. Unless you act within ten (10) days from the date of this
notice, a Judgment may be entered against you without a hearing
and you may lose your property or other important rights. You
should take this notice to a lawyer at once. If you do not have a
lawyer or cannot afford one, go to or telephone the following
office to find out where you can get legal help:
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Frank Federman, Esquire
Attorney for Plaintiff
FEDERMAN AND PHELAN, L.L.P.
Frank Federman, Esquire
Identification No. 12248
One Penn Center Plaza at
Suburban Station, Suite 1400
Philadelphia, PA 19103-1799
(215) 563-7000
FIRST HORIZON HOME LOAN
CORPORATION, F/K/A FT MORTGAGE
COMPANIES, D/B/A MNC MORTGAGE
Plaintiff
vs.
VALERIE L. YANNONE
GARY 5. YANNONE
Defendant(s)
TO: GARY S. YANNONE
1555 MCCLURE3 GAP ROAD
CARLISLE, PA 17013
DATE OF NOTICE: AUGUST 3, 2001
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO. 01-3989
THIS FIRM IS A DEBT COLLECTOR ATT PTI
THIS NOTICE IS SENT TO YOU IN AN M
INDEBTEDNESS REFERRED TO HEREIN,
FROM YOU WILL BE USED FOR THAT PUR S1~
PREVIOUSLY RECEIVED A DISCHARGE IN B
CORRESPONDENCE IS NOT AND SHOULD NOT B
ATTEMPT TO COLLECT A DEBT, BUT ONLY AS
AGAINST PROPERTY.
TO COLLECT A DEBT.
TO COLLECT THE
INFORMATION OBTAINED
F YOU HAVE
Y, THIS
STRUED TO BE AN
ORCEMENT OF LIEN
You are in default because you have failed enter a written
appearance personally or by attorney and file in writing with the
court your defenses or objections to the claims set forth against
you. Unless you act within ten (10) days from the date of this
notice, a Judgment may be entered against you without a hearing
and you may lose your property or other important rights. You
should take this notice to a lawyer at once. If you do not have a
lawyer or cannot afford one, go to or telephone the following
office to find out where you can get legal help:
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Frank Federman, Esquire
Attorney for Plaintiff
FEDERMAN andPHELAN
By: FRANK FEDERMAN
Identification No. 12248
One Penn Center at Suburban Station
Suite 1400
Philadelphia, PA 19103-1814
(2151563-7000
FIRST HORIZON HOME LOAN
CORPORATION, F/K/A FT
MORTGAGE COMPANIES, D/$/A
Attorney for Plaintiff
:CUMBERLAND COUNTY
Court of Common Pleas
MNC MORTGAGE
Plaintiff
CIVIL DIVISION
NO. 01-3484
vs.
VALERIE L. YANNONE
GARY S.YANNONE
Defendant(s)
VERIFICATION OF NON-MILITARY SERVICE
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the
Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the
following facts, to wit:
(a) that the defendant(s) is/are not in the Military or Naval Service 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 VALERIIE L. YANNONE is over 18 years of age and resides at
1002 WEST FOXCROFT DRIVE, CAMP HILL, PA 17011.
(c) that defendant GARY S. YANNONE is over 18 years of age, and resides at
1555 MCCLURES GAP ROAD, CARLISLE, PA 17013.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating
to unswom falsification to authorities.
~Vlo~ ~'~ dam,
FRANK FEDERMAN
Attomey for Plaintiff
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(Rule of Civil Procedure No. 236 -Revised)
FIRST HORIZON HOME LOAN :CUMBERLAND COUNTY
CORPORATION, F/K/A FT
MORTGAGE COMPANIES, DB/A :Court of Common Pleas
MNC MORTGAGE
CIVIL DIVISION
Plaintiff
NO. 01-3989
vs.
VALERIE L. YANNONE
GARY S.YANNONE
Defendant(s)
Notice is given that a Judgment in the above captioned matter has been entered against you on
AUGUST ~ , 2000.
By IS/ ~o ~- ~~ l/t7~~~'
If you have any questions concerning this matter, please contact:
FRANK FEDERMAN, ESQUIRE
Attorney for Filing Party
One Penn Center at Suburban Station
Suite 1400
Philadelphia, PA 19103-1814
(215563-7000
**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 BANHI2UPTCY AND THIS DEBT WAS NOT REAFFII2MED, THIS IS NOT
AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY
ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
,, , ._
CASE NO: 2001-03989 P
SHERIFF'S RETURN - REGULAR
COM1~'IONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FIRST HORIZON HOME LOAN CORP
VS
YANNONE VALERIE L ET AL
BRYAN WARD Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
YANNONE GARY S the
DEFENDANT at 2038:00 HOURS, on the 12th day of July 2001
ati 1555 MCCLURES GAP RD
CARLISLE, PA 17013 by handing to
GARY S YANNONE
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing His attention to the contents thereof.
Sheriffs Costs:
Docketing 6.00
Service 3.25
Affidavit .00
Surcharge 10.00
.00
19.25
Sworn and Subscribed to before
me this a3,~.eti day of
~, ~/ A.D.
..e. ~ .a~e:..~
/Pt~othonotary
So Answers:
R. Thomas Kline
07/16/2001
FEDERMAN & PHELAN
By. ~^ ~ d
Depu y Sheriff
SHERIFF'S RETURN - REGULAR
CASE NO: 2001-03989 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FIRST HORIZON HOME LOAN CORP
VS
YANNONE VALERIE L ET AL
KATHY CLARKE
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
VALERIE L
DEFENDANT
was served upon
the
, at 1416:00 HOURS, on the 13th day of July 2001
at 1002 W FOXCROFT
CAMP HILL, PA 17011
THOMAS BALDWIN, FA
by handing to
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 18.00
Service 9.10
Affidavit .00
Surcharge 10.00
.00
37.10
Sworn and Subscribed to before
me this d3ao( day of
~y-~i A.D.
to a OD _
~ Prothonota y
So Answers: ~/
.~~s~./
R. Thomas Kline
07/16/2001
FEDERMAN & PHELAN
By: ~~ c~~~
Deput heriff
~ v-
AFFIDAVIT OF SERVICE
PLAINTIFF FIItST HORIZON HOME LOAN CUMBERLAND COUNTY
CORPORATION, F/K/A FT MORTGAGE No.01-3989
COMPANIES, DB/A MNC MORTGAGE
Type of Action
DEFENDANT(S) VALERIE L. YANNONE -Notice of Sheriff s Sale
GARY S.YANNONE
SERVE VALERIE L. YANNONE AT
1002 WEST FOXCROFT DRIVE
CAMP HILL, PA 17011
Sale Date: DECEMBER 5, 2001
SERVED
Served and made known to 1I ~ / 2N N o N e_ ,Defendant, on the ~~ ~ day of~~_, 2005,
at ~/'~~ ,o'clock~.m, at ~~Oc1 ~ • l~o J(CtCO-f '~ (t.. ar^'V° ~ ,Commonwealth
of Pennsylvania, in the manner described below:
Defendant personally served. 1 ,,//~~
~_Adult family member with whom Defendant(s) reside(s). $elationship is a \ ~ e~ Ttn..~ I~ a ~ ~ "" N
Adult in charge of Defendant(s)'s residence who refused to give name or rela onship.
Manager/Clerk of place of lodging in which Defendant(s) reside(s).
Agent or person in chazge of Defendant(s)'s office or usual place of business.
an officer of said Defendant(s)'s company.
Other:
r ,l _ _r..
Description: Age ~o Height Weight IS S Race w~^ Sex ~ Other ~~+se5
I, CI~eNce ~.,, C~ti'Fy , TR•, a competent adult, being duly sworn according to law, depose and state that I personally handed
a true and correct copy of the No ' set forth herein, issued in the captioned case on the date and at
the address indicated above. Notarial seai
Stacy L. Heefner, Notary Public
Chambersburg Boro, Franklin County
Sworn to and sups~ bed My Commission Expires A 5, 2002
bef e e s Idh-day Member, Pennsylvania Ass iatio otaries
of L'~~, 2001,.
U V `U~ Q~~(J~LL'71.J NOT SERVED
On the _ ~_ day of , 200_, at o'clock _.m, Defendant NOT FOUND because:
hfoved Unknown No Answer Vacant
Other:
Sworn to and snbs'erbed
before me this -day
of _ _~, 200 _.
Notary: By:
Attorney for Plaintiff
Frank Federman, Esquire - I.D. No. 12248
One Peun Center Suburban Station, Suite 1400
Philadelphia, PA 19103
(215) 563-7000
!";
a_~
_
.,
t-:
r "<~
a ~.i
First Horizon Home Loan Corporation In The Court of Common Pleas of
F/k/a FT Mortgage Companies, d/b/a Cumberland County, Pennsylvania
MNC Mortgage Writ No.2001-3989 Civil Term
VS
Valerie L. Yannone and Gary S. Yannone
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED pursuant to instructions from Attorney Frank Federman.
Sheriff s Costs
Docketing
Surcharge
Posting Handbills
Law Library
Prothonotary
Share of Bills
Mileage
Levy
Advertising
Certified Mail
Poundage
Postpone Sale
Law Journal
Patriot News
30.00
30.00
15.00
.50
1.00
25.66
16.25
15.00
15.00
2.44
19.64
493.25
33 7.65
$1001.39 paid by attorney
Sworn and subscribed to before me S~ s eri~5 ~'~
This i2 ~' day of id?u.u~.,~•-~~
R. Thomas Kline, Sheriff
2001, A.D. ~ ~7
BY~
Prothonotary Real E to Deputy
~, ~
~3Y9~1
j/9GFs~
FIRST HORIZAN HOME LOAN CORPORATION,
'~ F/K/A FT MORTGAGE COMPANIES, DB/A MNC CUMBERLAND COUNTY
MORTGAGE
COURT OF COMMON PLEAS
Plaintiff,
v. CIVIL DIVISION
VALERIE L. XANNONE NO.Ol-3989
GARY S.YANNONE
Defendant(s).
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. l)
r
DB/A MNC MORTGAGE, Plaintiff in the above action, by its attorney, FRANK FEDERMAN,
ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following
information concerning the real property located at LOT #13, GRANT COURT WER'FZ RUN
HEIGHTS. CARLISLE, PA 17013
1. Name and address of Owner(s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
VALERIE L. 1002 WEST FOXCROFT DRIVE
YANNONE CAMP HILL, PA 17011
1555 MCCLURES GAP ROAD
GARY S. YANNONE CARLISLE, PA 17013
2. Name and address of Defendant(s) in the judgment:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Same as above
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
t4.
5.
6.
Name and address of the last recorded holder of every mortgage of record:
NAME LAST'KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
Name and address of every other person who has any record lien on the property:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
Name and address of every other person who has any record interest in the property and whose
interest maybe affected by the sale:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
Name and address of every other person whom the plaintiff has knowledge who has any interest
in the property, which maybe affected by the sale:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Tenant/Occupant LOT #13, GRANT COURT WERTZ RUN
HEIGHTS
CARLISLE, PA 17013
Domestic Relations of Cumberland 13 North Hanover Street
County Carlisle, PA 17013
Commonwealth of Pennsylvania p0 Box 2675
Department of Welfare Harrisburg, PA 17105
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. Sec. 4904 relating tc
August 28.2001
DATE
FIRST HORIZON HOME LOAN CORPORATION,
F/K/A FT MORTGAGE COMPANIES, DB/A MNC
MORTGAGE
Plaintiff, -
v.
VALERIE L. YANNONE
GARYS.YANNONE
Defendant(s).
TO: VALERIE L. YANNONE
August 29, 2001
1002 WEST FOXCROFT DRIVE
CAMP HILL, PA 1701,1
CUMBERLAND COUNTY
. No. 01-3989
GARY S. YANNONE
1555 MCCLURES GAP ROAD
CARLISLE, PA 17013
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WII,L BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A pISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED
TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.**
Your house (real estate) at LOT #13, GRANT COURT WERTZ RUN HEIGHTS,
CARLISLE, PA 17013 is scheduled to be sold at the Sheriffs Sale on DECEMBER 5, 2001 at 10:00
a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the
court judgment obtained by FIRST HORIZON HOME LOAN CORPORATION. F/K/A FT
MORTGAGE COMPANIES. D/B/A MNC MORTGAGE (the mortgagee) against you. If the
Sheriff s sale is postponed, the property will be relisted for the MARCH 6, 2002 Sheriffs Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
call: (215) 563-7000.
2. You maybe 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.
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.)
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling (2151563-7000.
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 (717) 240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you. ,
6. You maybe entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after the distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
,,~
ALL THAT CERTAIN piece or parcel of land with the buildings and improvements thereon
rected, if any, situate in Wentz Run Heights, North Middleton Township, Cumberland County,
~otnmonwealth of Pennsylvania bounded and described in accordance with Final Subdivision Plan
for Phase No. II for "Wertz Run Heights," recorded on October lb, 1996, in Cumberland County
Plan Book 73, Page 47, as follows, to wit:
BEGINNING at a point, said point being located on the Eastern right-of--way line of Graft Court at
[he common front property corner of Lot #14 and Lot #13 of Wertz Run Heights, Phase 2; thence
along the Eastern right-of-way line of Granc Court Noah 37 degrees 15 minutes 00 seconds East, a
distance of 15.88 feet to a point; thence along the same on the azc of a curve, curving to [he right
having a radius of 10.00 feet, an arc length of 17.45 feet and a central angle of 49 degrees,59
minutes 41 seconds to a point; thence along the same on the arc of a curve, curving to the left
having a radius of 50.00 Feet. an arc length of 122.17 feet and a central angle of 139 decrees 59
minutes 41 seconds to a point at Lot #12 of Wertz Run Heights, Phase 2; thence along Lot #12
North 37 degrees 15 minutes 00 seconds East, a distance of 105.00 feet to a point at Lot #1 of
Wertz Run Heights, Phase 2; thence along Lot #1 South 73 degrees 45 minutes 31 seconds East, a
distance of 255.33 feet to a point at land now or late of Kollar and Costopoulos, Kingsbrook Phase
VII; thence along a portion of land now or late of Kollar and Costopoulos, Kingsbrook Phase VII;
thence along a portion of land now or late of Kollar and Costopoulos, Kingsbrook Phase VII, land
now or late of John I., Lois G., and Betsy K. Taylor, land now or late of David J. and Shazon J.
Schaffer, land now or late of Steven L. and Tammy A. Fisher; and a portion of land now or late of _
Barry W. and Sandra E. Swope South 18 degrees 43 minutes 30 seconds West, a distance of 285.00
feet to a point at Lot #14 of Wertz Run Heights, Phase 2; thence alongLot #14 North 71 degrees 16
minutes 40 seconds West, a distance of 144.17 feet to a point; thence along the same North 52
degrees 45 minutes 00 seconds West, a distance of 167.23 feet to a point on the Eastern right-of-
way line of Grant Court, the point of Beginning.
SAID LOT CONTAINS 73,192.86 squaze feet or 1.680 acres.
BEING Lot #13 of the Final Subdivision Plan of Wertz Run Heights, Carlisle, Cumberland County,
Pennsylvania, recorded in Plan Book 73, Page 47, on October 16, 1996.
TAX PARCFJ-. #29-05-0429-034
TITLE TO SAID PREMISES IS VESTED IN Gary S. Yannone and Valerie L. Yannone, his wife
by Deed from Kollar and Costopoulos, a PA General Partnership comprised of William C. Kollar
and William C. Costopoulos dated 6/11/98 and recorded 6/16/98 in Record Book 179 Page 283.
WRIT OF EXE~UTI®N andlor ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 01-3989 CIVIL I9
CIVIL ACTION -LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due First Horizon Home Loan Corp. f/k/a FT Mortgage
Companies, ~d/b/a M[~ Mortgage PLAINTIFF(S)
from Valerie L. Yannon, 1002 W, Foxcroft Dr., Camp Hi11 PA 17011 and Gary S.
Pannone, 1555 McClures Gap Road, Carlisle PA 17013.
(1) You are directed to levy upon the property of the defendant(s) and to sell Real estate located
at Lot #13, Grant Court Wertz Run Heights, Carlisle PA 17013. (See
attached legal description.)
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that:. (a) an attachmern has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the account of the defendant(s) and irorrr delivering any property of the defendant(s) or otherwise disposing
thereof;
(3) Ifpropertyofthedefendant(s)notlevieduponansubjectioattachmentisfoundinthepossessionofanyoneother
than a named garnishee, you are directedto not'rfy himlherthat he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due $142,749.67
Interest 8/16/01 - 12/5/O1 $2,605.17
per iem
e.T<v's Comm
A~tyPaia $128.35
Plaintiff Paid
L.L.
Due Prothy_
Other Costs
Date: September 10, 2001
CURTIS R, LONG
Prot ono ary, Civil
by. ~` -
REQUESTING PARTY:
Name Frank Federman, Esq.
Address: 1617 JFK Blvd; Ste 1400
Philadelphia PA 19103 1814
Attorney for: Plaintiff
Telephone: (215) 563 7000
Supreme Court ID No.
12248
$.50
$1.00
Deputy
:,,r~,.~
R~~L~rsLL~AT~ SALE No. ~~
On September 17, 2001, the sheriff levied upon the
defendant's interest in the real property situated in North Middleton
Township, Cumberland County, PA, known and numbered as
Lot # 13, Grant Court, Wertz Run Heights, Carlisle, and more fully
described on Exhibit "A" filed with this writ and by
this reference incorporated herein.
Date: September 17, 2001
By: ~~s~-N .~v~t.~~,
Real Estate Deputy
0
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ss.
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
Law Journal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
October 12, 19, 26, 2001
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
Roger orgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
26 day of OCTOBER. 2001_
LOTS E. SNYDER, Notary Publk
CarNsle Bao, Crran6erland niy
My Comaaseioa Expires A~nch 5,2505
~- -~~~~
REAL ESTATE SALE NO. 36
Writ No. 2001-3989 Civll
First Horizon Home Loan
Corporation. f/k/a FT Mortgage
Companies, d/b/a
MNC Mortgage
vs.
Valerie L. Yannone and
Gary S. Yannone
Airy.: Frank Federman
ALLTHAT CERTAIN piece or par-
cel of land with the bulldings and
improvements thereon erected, if
any, situate m Wentz Run Heights.
North Middleton Township, Cum-
berland County. Commonwealth of
Pennsylvania bounded and de-
scribed in accordance with Final
Subdivision Plan for Phase No. II
for "Wertz Run Heights," recorded
on October 16. 1996, in Cumber-
land County Plan Book 73, Page 47,
as follows, to wit:
BEGINNING at a point, said point
being located on the Eastern
right-of--way line of Grant Court at
the common front property comer
of Lot # 14 and Lot # 13 of Wertz
Run Heights, Phase 2; thence along
the Eastern right-of-way line of
Grant Court North 37 degrees 15
minutes 00 seconds East, a distance
of 15.SS feet to a point; thence along
the same on the arc of a curve, curv-
ing to the nght having a radius of
10.00 feet, an azc length of 17.45
feet and a central angle of 49 de-
grees 59 minutes 41 seconds to a
point; thence along the same on the
azc of a curve, curving to the left
having a radius of 50.00 feet, an
azc length of 122.17 feet and a cen-
tral angle of 139 degrees 59 min-
utes 41 seconds to a point at Lot
#12 of Wertz Run Heights, Phase
2; thence along Lot #12 North 37
degrees 15 minutes 00 seconds
East, a distance-of 105.00 feet to a
point at Lot # 1 of Wertz Run Heights,
Phase 2; thence along Lot #1 South
73 degrees 45 minutes 31 seconds
East, a distance of 255.33 feet to a
point at land now or late of Kollar
and Costopoulos, Kmgsbrook Phase
- VII: thence along a portion of land
now or late of Kollar and Costop-
oulos, Ktngsbrook Phase VII; thence
along a portion of land now or late
of Kollar and Costopoulos, Kings-
brook Phase VII, land now or late of
John I., Lois G., and Betsy K. Tay-
lor, land now or late of David J. and
Sharon J. Schaffer, land now or late
of Steven L. and Tammy A. Fisher,
and a portion of land now or late of
Barry W. and Sandra E. Swope
South 18 degrees 43 minutes 30
seconds West, a distance of 285.00
feet to a point at Lot #14 of Wertz
Run Heights, Phase 2; thence along
Lot #14 North 71 degrees i6 n•,LZ-
utes 40 seconds West, a distance
of 144.17 feet to a point; thence
along the same North 52 degrees
45 minutes 00 seconds West, a dis-
tance of 167.23 feet to a point on
the Eastern right-of-way line of
Grant Court, the point of Beginning.
SAID LOT CONTAINS 73,192.86
squaze feet or 1.680 acres.
BEING Lot # 13 of the Final Sub-
division Plan of Wertz Run Heights.
Cazllsle, Cumberland County, Penn-
sylvania, recorded m Plan Book 73,
Page 47, on October 16, 1996.
TAX PARCEL #29-05-0429-034.
TITLE TO SAID PREMISES IS
VESTED IN Gary S. Yannone and
i Valene L. Yannone, his wife by Deed
from Kollar and Costopoulos, a PA
General Partriership comprised of
William C. Kollar and William C.
Costopoulos dated 6/11/98 and
recorded 6/16/98 in Record Book
179. Page 283.
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 printerd and published in
their regular daily and/or Suntlay/ 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 mati:er of said printed
notice or advertising, and that all of the allegations of this statement as to the time, place and character of
publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds in and for said County of Dauphinj ~In Miscellaneous Book "M",
Volume 14, Page 317. ,~ /
PUBLICATION
COPY
SALE #36
w-SPfr'i8"2nti'sabsertlyed-befere~+1~. is 19th day Nav~hber 2001 A.D.
NotaAai Seal
Terry L. Russell, Notary Public /~//~~,'~/
Hamsburg, Dauphin County %~~_ `_
My Commission Expires June 6,2002 N ARY PUBLIC
Member, Pennsylvania Association d Note
commission expires .June 6, 2002
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates $ 356.15
Probating same Notary Fee(s) $ 1.50
Total $ 337.65
Publisher's Receipt for Advertising Cost
The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general
circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have
been duly paid.
By ....................................................................
ctvn term
~~First Horizon Home Lqan Corporation
--fAJa Ff Mortgage Companies,
- dlb/a MNC Mortgage
`--- Valerie.'annone
°-~---- Gary S: Pannone
-i1tty: Frank Federman
~: DESCRIPTION
ALL 'CHAT CERTAIN piece or parcel oC [and
=with the buildings and improvements [hereon
--:ereeted, if any, situate in Wentz Run Heighu,
~ordi Mtddtemn Township, Cumberland County,
ommomvealth of Pennsylvania, bounded and
descnbed in accordance xolh final Subdivision
Mort Pdr Phase No. H for "Wertz Run Heights;'
s -rxarded_on October 16, 1996, in Cumberland
Iut #]3 of Wertz Run Heighu Phase 2; thence
Tong IheFastem fight-o(-way line of Grant CovR
"North 37 degrees 15 minutes 00 seconds East, a
~utan~ of 15.86 Put to a point; thence along the
~~t~dre arc of a curve, tarring to the right
=ttaviug a ntGus of 10.00 feet, w arc length of
I`7~$5 Feet and a ce~tml angle of 49 degrees 59
mindfes_41 suonds to a point thence along [be -
~s~vrCptr-me'arc of~a ddrve, curving [o the leR
mg- a radius of "50.00 fee4 an am Length of -
._ - -l7 feet and a cFhdal angle of l39 degrees 59
mom"-SithiesdL seconds to a point of Lnt #12 of Wertz
a~`Run Heighu,_Phas~2~ thence along Lot H12
Nonif_37 diegrees 15~minutes OD suonds East, a,
'=dtstance oflOSCOte`etta a pdint 5t Lo! dl of
`~Wetbz Run Heights, Phase 2; thence slang Lot #t
auSir 73 degrees 45 minutes 31 seconds East, a
~rs~ce df 255.33 `-et to a point at land now or
mate ofKollas and Costopoulns, Kingsbrook Phase
VII; thence along a potton o{ land now or ]ale of
~iCOitas and CostoLouios, Kingsbrook Phaze VH;
thence along a pdtt•:on of land now or fate of
Kollas and Costopoulos, Kingsbrook Phase VII,
Sand norv cr ]ate of John L, Lois ~., and Betsy K.
--_Taylw,landnow or late of David J, and Sharon 1.
~S_chatfer, land now or (ate of Steven L. and
TammyA. Esher, and a portion of [and now ar `
elate of Barry W. and Sandra E. Swope South IS
adegaes 43 minutes 30 seronds WesS a distance of
-385.00 Put to a point at Lat Ill4 of Wertz Run
ETeigtiu, Phase 2; dtencc along Lot #14 North 71
-uegrees I6 minutes 40se:onds West, a distanceaf
144.17 fee[-to z-point; thence along the same
°-North 52 degrees 45 minutes 00 seconds West, a
--distance of 167.?3 feet to a point on fire Easlem
~-right-0Fway live aF Grant Court, the point oF-
- BEGINNEVG.
--SAID LOT contains 73,192.86 squaze feet or
~I:680 attes.- -
BE.INGS.at913 of the Final Subdivision Plan of
Wertz Run Heighu, Cazlisle, Cumberland County,
Pennsylvania, tucrded in Plan Book 73, Page 47,
vested m Gary S.
[one, his wife, by -
ulas, a PA General
lam C. Roltas aod
FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF
ONE PENN CENTER AT SUBURBAN STATION
PHILADELPHIA, PA 19103 COURT OF COMMON PLEAS
(215L563-7000 CIVIL DIVISION
FIRST HORIZON HOME LOAN CORPORATION, F/K/A FT MORTGAGE COMPANIES, DB/A MNC
MORTGAGE
4000 HORIZON WAY
Il2VING, TX 75063
v. NO. 01-3989
VALERIE L. YANNONE
GARY S.YANNONE
CUMBERLAND COUNTY
PRAECIPE TO MARK JUDGMENT SATISFIEA
TO THE PROTHONOTARY:
Kindly mark judgment in the above captioned matter "Satisfied" upon payment of your costs only.
~Cl~
RANK FEDERMAN, ESQUIRE
February 5, 2002
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