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Home My WebLink About03-2426 FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 IRWIN UNION BANK AND TRUST COMPANY 12677 ALCOSTABLVD SUITE 500 SAN RAMON, CA 94583, ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM Plaintiff v. NO. 03 - dl.4 ~'=- Ci u'l...<-rE/UY1 CUMBERLAND COUNTY ROBERT A. POORMAN AIKIA ROBERT L. POORMAN DEBORA A. POORMAN 3815 DORSET DRIVE MECHANICSBURG, PA 17055 Defendant( s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **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 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. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or 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 COUNfY CUMBERLAND COUNfY BAR ASSOCIATION 2 LffiERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 Loan #: I 172065NZB IF THIS IS THE FIRST 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 VALIDITY 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 THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES 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 AFfER YOU HAVE RECEIVED THIS 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 REQUIRES 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. 1. Plaintiff is IRWIN UNION BANK AND TRUST COMPANY 12677 ALCOSTA BLVD SUITE 500 SAN RAMON, CA 94583, 2. The name(s) and last known addressees) of the Defendant(s) are: ROBERT A. POORMAN AlK/A ROBERT L. POORMAN DEBORA A. POORMAN 3815 DORSET DRIVE MECHANICS BURG, PA 17055 who is/are the mortgagor(s) and real owner(s) ofthe property hereinafter described. 3. On 9/8/00 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. 1639, Page 940. 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 12/15/2002 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. 6. The following amounts are due on the mortgage: Principal Balance Interest 11/15/2002 through 05/19/2003 (per Diem $29.91) Attorney's Fees Cumulative Late Charges 09/08/2000 to 05/01/2003 Cost of Suit and Title Search Subtotal $84,624.42 5,563.26 1,250.00 587.72 $ 550.00 $ 92,575.40 Escrow Credit Deficit Subtotal TOTAL 0.00 0.00 $ 0.00 $ 92,575.40 7. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant( s) on the date( s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or haslhave been denied assistance by the Pennsylvania Housing Finance Agency. 9. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 92,575.40, together with interest from 05/19/2003 at the rate of $29.91 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. FEDERMAN AND PHEL~ 1}J? /1 '$~ By: ~.HanUmn FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff o'lL1. TH..4. ~.. CERT All" tract or Parcel c..f Icmd cme/ p,'cmi:/cs, sifuatf", /)';11:: ami bflillg i;i ,IIa Tvwllshi"J 0" Harnpd"a~ "It tlla COIIlJty of Ctnnb~rland 1%I,d COllllllOlr\"'caltll of P"."l1sv!vall1r1. ~:::Jr'.: p:lrlic:..,:',ri)' tl.!.~c ,,.ib..;'d 'l.of p.I/Ow,v: .rJci:t;; LI,;; #1-/7. ~'t:il1~~""'Q<;ld. J~;'CI.'r.c If. (7S rC'.::t;:",;(!t% ;n Cw"hcr!~lld CO:l1l1Y 1"/,:1: 8:::..-/' _f~. P":::,c ~.,.!. murc.: J)cJ"l;cul!lr{~' ~(JII;h:~d ,'ud desc,'io..r/ cJ:: JoI:oH,.-';. to ~".:t: !!EOIN1VIl'!O ai r.I ;:JQiHt ?17 t;u- SOU", :rjtiff nf r;or~el l),-;\.c :..tid po;u: r.lsa !:.::b,g", ./i....tC'IIIc,z '?f.W...:. ,"hOl;dra~! ivinct\'-For:r ancl Olle O"c-U.,.m!,.qclt!lsj'lilc/ (694.01' Hlest OJ'tllti iufcn:r.c:lcJ/l oflllc J V..-:.~r 3idd of Cilipl'tmlam Road .md the Soulh side of DOI'sal Driva, ,hence by rhe lil1C~ of LCIIVo, IJS Southforry dcgre.:s thirty-lwo mbrules lW~Jlly seconds &Y.:s1 (S -If) 32' 2(J" H? (I disltlncr:: of Our:: J-{uud, oed N"/c?tP.,H ,'me{ ~ffVelZty-Six OIJa-H:.:nc!rcdtitsfec.:r (J /9. 76;10 " puillt ill A 7(t;T r;g/il qr"'~l" a,lillco :"/ ':"!:JI' J,'o. ./1$6 /!ampdclI Square Section/, PIa" l1ot;lk S I, Paga Z,' t:".J"r.~ l,y ,rtm:~ umf IJm ^~o, ./67 No...':', fzfi;\I dfl::rerufV'leal' m;'lu'tUfCJr~"-!'wo ,rer.rm.Js 'Vest (N 50! S' 12" fJ? :t .U"tcIIICc.! ofNillery..F'i",'(~ :JJld rifty~SLT.' OJJ..e-l-Iu;"L"adt"~./i!.al (9-'i.56? 10 "l'oillt; "'CiUCI!! :JY Lot Nc). Iii;' NO,'III ....;.'.'Y-Ilrrt:f! ."f.?g"cr..~ ;hir/call mt1I1t1~sf",.tY-fil'f.: .-rtZCOI7cLs ~Ve:si (h'if3 I;]' 45" I'V) a .:!.'::l.'mcc ~ll:V",- unci . V;"e;y-"'~,:~II1 One I-I"..dr.:c/tll.:; frJoit (4.9S:) 10 n pc:itll at !ine: of L~t Nu. 146: dll.!Jlc:-,:, l~y SU,UfI oVQrll, j..,rly ../~g...*,'es thlr'y-t'\~.r, IU..lfOUc:.s 1\I.'e:nl>' sc'colufs ~":i" ~.".r 4032' 20" E) I: clistanc~ cf ()1t2 1 jUII(tra,1 Tr1'I.mly-Two and NilU!tacl1 Onn.-/:bmci,.etlu7$ leal (j 12.19 J 10 a poi"t 011 lite SuI/I!' side o..r Dor.'~e/ D:-il'c:; t!re/lca by .~al1le $Qlllo,IIfortY-llil1e dagrcJes IW~"'Y-::C:I'C:lIl11;1JIIICS .'01'(,. .,'(u~ond.cr FortSt (S ':9 27' 40'" S) a dislcnc:.: afOm.: !-IlI/,clrcd leel (100.00) 10 11t(~ Pl{l~;~ q{ Begilllling_ CO/v r ~_!i'v"JNG 1 Z. ()(.~.3() .'i.]U~/"C feet_ *,,'(2WI1 u;;c/ mJJ::/.;c:-~d ~ 3815 Dorsel Drivc, J-fec/zemicrvlII-g, F'.-1 ; 70~S J1EfNG tllt:~ .VGmc p"~Nisc:: which Rlt."Clon Hom~~. IIIC, A Pcu1ll3yl"nlliCl CO'1JC'ralim' by i/.~ deed cialcd .'Wc~, cI: 27. 199,' r.me: r'Jccr-ded April 9, 1991 i:1 :he Recordc.:,- ofDcc.:d.v OJ;7cf.f ill am/for I-:::::":b~.!-I!:,,,,' ,-',,~u':ll' ,'JI :lo,-:.:"":'-:;.'i. P"~tI 67r-. g;':lJ1:.:d a;:d ;:OIiFc:.....C:! lUlU: .Ia:llCS R. IJc!~~111CIII (lilt! !_.::ll....a 1: !-1__-;;!!."::I:I, life: ~__J,"a'!l~",~ I'llr,-ill. BEING KNOWN AS: 3815 DORSET DRIVE. . ~ VERIFICA nON FRANCIS S. HALLINAN, ESQUIRE hereby states that he is attorney for Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that he is authorized to make this verification pursuant to Pa. R. C. P. 1024 ( c ), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of its knowledge, information and belief. Furthermore, it is counsel's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C. S. Sec. 4904 relating to unsworn falsification to authorities. ~JI)J?L Francis S. Hallinan, Esquire Attorney for Plaintiff DATE: 0~' ({f-(f3 ~~ ~ Crt U1 , - ~ ~ w 0 ~ - f' ~ ~ r5 0 0 ~ -J:-- 0 {=, 0 t C (.-.l :,::.,.. - .j--~ ~~F :'c -- . :.;:.~ z:-.. -< '. , ' z; r'V \"-.1 en' -<;':.' tv '-.,,....' c:C . ';2, ~...-. '""D , Z'.- ) -'-1 >~:> . -',~~ (": N (,) rn 7, --' :<. 'Jo' ~t> (.X) ~ SHERIFF'S RETURN - REGULAR CASE NO: 2003-02426 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND IRWIN UNION BANK AND TRUST CO VS POORMAN ROBERT A ET AL BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon POORMAN ROBERT A A/K/A ROBERT L POORMAN DEFENDANT , at 1101:00 HOURS, on the 11th day of June at 3815 DORSET DRIVE MECHANICSBURG, PA 17055 MATTEHW TOWNSEND, SON by handing to the , 2003 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 18.00 9.66 .00 10.00 .00 37.66 Sworn and Subscribed to before {J:..> me this ~o - day of ~ ;Jov..J A.D. (l . . () In., ill.) ~ I~othonotary I So Answers: r~~ R. Thomas Kline 06/11/2003 FEDERMAN & By: .Deputy Sher~ SHERIFF'S RETURN - REGULAR CASE NO: 2003-02426 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND IRWIN UNION BANK AND TRUST CO VS POORMAN ROBERT A ET AL BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE POORMAN DEBORA A was served upon the , at 1101:00 HOURS, on the 11th day of June , 2003 DEFENDANT at 3815 DORSET DRIVE MECHANICSBURG, PA 17055 MATTHEW TOWNSEND, SON 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 Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 Sworn and Subscribed to before me this .l-D ~ day of ~ ~ A.D. Ckten~'~' So Answers: ~["J ~P' /~~ 1 .;;:I~''''~~1'':~ R. Thomas Kline 06/11/2003 FEDERMAN & By: PHE~ (( Deputy Sheriff FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SffiTE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 IRWIN UNION BANK AND TRUST COMPANY 12677 ALCOSTA BLVD. SUITE 500 SAN RAMON, CA 94583 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 03-2426- CIVIL TERM ROBERT A. POORMAN AIKIA ROBERT L. POORMAN DEBORA A. POORMAN Defendant(s). PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against ROBERT A. POORMAN AlKlA ROBERT L. POORMAN and DEBORA A. POORMAN, 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 Interest from 5/20/03 to 7/15/03 TOTAL $92,575.40 $1,704.87 $94,280.27 I hereby certify that (I) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. - ~J'fl..il.ri...- FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICAJr. D. t /) DATE:Je,. Iii?, ?-iX)~ (~L/Jj~,;u /). .A~ PRO PROTHY ~ 0 FEDERMAN AND PHELAN, LLP ;.J.ANK FEDER.l\i1AN. ESQ.. Id, "lo, 12248 LAWRENCE T, PHELAN. ESQ" Id, No, 32227 FRANCIS S, HALLINA"l, ESQ" Id, No, 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (710) 'lii-7000 ATTORNEY FOR PLAINTIFF IRWIN UNION BANK AND TRUST COMPANY Plaintifr : COURT OF COMMON PLEAS : CIVIL DIVISION Vs, : CUMBERLAND COUNTY ROBERT A POORMAN NKJA ROBERT L POORMAN DEBORA A POORMAN Defeodanis : NO, 03-2426 CIVIL TERM TO: ROBERT A. POORMAl'l' AlK/A ROBERT L. POORMAN 3815 DORSET DRIVE MECHANICSBURG, PA 17055 FILE ~,. ~:, "-'__I I DATE OF NOTICE: .JULY 2. 2003 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY IMPORT ANT NOTTeii', You are in default because you have failed 10 enter a written appearance personally or by attorney and file in writing wi1h 1he court your defenses or objections 10 1he claims set forth againsl you. Unless you act wilhin ten (10) days from 1he dale ofthi, notice, a Judgmenl may be entered againsl you wi1houl a hearing and you may lose your property or o1her impottanl rights, You should lake this notice 10 a lawyer al once, If you do nol have a lawyer or cannol afford one, go to or lelephone 1he following office to fmd oul where you can gel legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA I70B (717) 249-3166 FRANK FEDERMAN, ESQUIRE LAWRENCE T, PHELAN, ESQUIRE FRANCIS S, HALLINAN, ESQUIRE Attorneys for Plainliff rEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ" Id. No. 12248 LA WRENCE T. PHELAN, ESQ" Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (71,) ,(ij-7000 ATTORNEY FOR PLAINTIFF IRWIN UNION BANK AND TRUST COMPANY Plaintiff : COURT OF COMMON PLEAS : CIVIL DNISION Vs. : CUMBERLAND COUNTY ROBERT A. POORMAN AiK/A ROBERT L. POORMAN DEBORA A. POORMAN Defendants : NO. 03-2426 CIVIL TERM TO: DEBORA A. POORMAN 3815 DORSET DRlVE MECHAlYICSBURG, PA 17055 DATE OF NOTICE: ,TFT ,y 2, 2003 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE,lF YOU HAVE PREVlOUSL Y RECENED A DISCHARGE IN BANKRUPTCY, THTS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. TMPORT ANT NOnCE You are in default because you have failed 10 enter a written appearance personally or by attorney and file in writing wiih ihe court your defenses or objections 10 ihe claims set forth againsl you. Unless you act within ten (10) days from ihe dale of this notice, a Judgment may be entered againsl you wiihout a hearing and you may lose your property or oiher Unportanl righls. You should take this nolice 10 a lawyer at once. If you do nol have a lawyer or cannot afford one, go 10 or telephone ihe following office to fmd oul where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY A VENUE CARLISLE, PA 17013 (717) 249-3166 FRANK FEDERMAN, ESQUJRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S, HALLINAN, ESQUJRE Attorneys for Plainliff .::>rl.t:;Kl..:,i:' 'b KJ::~.;'l'UlU'\j - REGULArt . CASE NO: 2003-02426 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND IRWIN UNION BANK AND TRUST CO VS POORMAN ROBERT A ET AL BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon POORMAN ROBERT A A/K/A ROBERT L POORMAN the DEFENDANT at 1101:00 HOURS, on the 11th day of June , 2003 at 3815 DORSET DRIVE MECHANICSBURG, PA 17055 by handing to MATTEHW TOWNSEND, SON 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 18.00 9.66 .00 10.00 .00 37.66 So Answers: ~r4 / ~;;?' r t,..(",J!~J"'..~/ /.,z_", .....;...;.0::.........-..- ""-o-""'~-"-- :I R. Thomas Kline day of 06/11/2003 ';; FEDE:" & PHEA~~ AtulP Deputy Sherif~ - Sworn and Subscribed to before me this A.D. Prothonotary SHERIFF'S RETURN - REGULAR _ CASE NO: 2003-02426 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND IRWIN UNION BANK AND TRUST CO VS POORMAN ROBERT A ET AL BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon POORMAN DEBORA A , at 1101:00 HOURS, on the 11th day of June DEFENDANT at 3815 DORSET DRIVE MECHANICSBURG, PA 17055 MATTHEW TOWNSEND, SON by handing to the , 2003 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 6.00 .00 .00 10.00 .00 16.00 Sworn and Subscribed to before me this day of A.D. Prothonotary So Answers: -;,?'--'i~l~:.~;:'- ",.~ '. ,.:~'~:.?- ,,';(0,,1'0'':''''';''''';,'. R. Thomas Kline 06/11/2003 FEDERMAN & PHE~ fI,A Deputy Sheriff By: (":) ~ t~~ 8 r :t? ~ V 3 <? ~ p:. ~~:::1? ~ ~ o ,-, 0 <" ( FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PIDLADELPIDA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF IRWIN UNION BANK AND TRUST COMPANY 12677 ALCOSTA BLVD. SUITE 500 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 03-2426- CIVIL TERM ROBERT A. POORMAN AlKlA ROBERT L. POORMAN DEBORA A. POORMAN 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 ROBERT A. POORMAN AlKlA ROBERT L. POORMAN is over 18 years of age and resides at , 3815 DORSET DRIVE, MECHANICSBURG, P A 17055 . (c) that defendant DEBORA A. POORMAN is over 18 years of age, and resides at, 3815 DORSET DRIVE, MECHANICSBURG, PA 17055. This statement is made subject to the penalties of 18 Pa. C,S. Section 4904 relating to unsworn falsification to authorities. ~ (H1J.~~>~.L(j . JUri 0 ~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PIDLADELPIDA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF IRWIN UNION BANK AND TRUST COMPANY Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DMSION ROBERT A. POORMAN A/KIA ROBERT L. POORMAN DEBORA A. POORMAN NO. 03-2426- CIVIL TERM Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: o an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ....... ~ () 11. ~.JU:L fI JJi QrIoJ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 IRWIN UNION BANK AND TRUST COMPANY Plaintiff, v. No. 03-2426- CIVIL TERM ROBERT A. POORMAN A/KIA ROBERT L. POORMAN DEBORA A. POORMAN Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $94,280.27 Interest from 7/15/03 to DECEMBER 10, 2003 (per diem -$15.50) $2,294.00 and Costs TOTAL $96,574.27 ~~ (Jr/..-; FRANK FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property. No. ~;:$ o~ "'> <..:I ~~ ll.'" ZZ OZ :E~ :E;;'; 0... uz ~OJ 00 ...u ~~ g~ u~ >"'1>"'1 == "':E ZOJ ...u r-. _:.1 ,_.... "1 > , "'5 "':-=-, U ... ~ ... ~ ~~ ~~ =:E ZO ou ... Z OJ Z ~ ... ~ ~ o o ll. ..l ~~ ~~ ~O ~~ << ~~ ~~ 0>"'1 O~ ll. < ~ >"'I = ~ <Ii .. ~~ ~j ~ ~ ~ 0:. ~ - , , - I I \ 8:::2eQO ..J ~... .Ot-, ~ ~~~~O:r) lJi ~ )~ Z o ... ... OJ u ~'E' >"'I = ~ ~ 0'<:: ... :: til~ ~~ ~ os 01>/) ~i ~6 ... u >"'I ~ ll. - - \:B:1 ~ @ -.: . ~l>)o -i::i v - ~ 1:::1 ,~ E .~ oj ii: ... <B ;>, v ~ < Vl Vl Vl Vl -= -= r-- r-- ..... ..... << ll.ll. gr5 OJ~ == "'''' UU ~~ == UU >"'1>"'1 :E:E ~rJ' >> tiltil ~~ ...... >"'1>"'1 ~~ 00 ~~ Vl Vl ..... ..... 00 00 .... .... Vi <Jl V ... -c:l -c:l < - <' V> ~ C\, to "t CJ .,j v t: v <Jl V .D ~ <Jl ... v 1a- 0- ~ ::;:- - ~ - j ~ c] J & ALL THAT CERTAIN tract or rareel of IMd aD(! premises, sit"iIl', lying and being Utlhe Townsl1ip of Hampden in lhe County of Cumberland and Commonwealth of Pennsylvania, more particularly described as fuUows: BEING Lot N47, Kin!!"wood. Pbll$llll. as recorded in Cumberland CounlY Plan Book 55, Page 93, more pan.ieularly bounded and described as follows, to wit BEGINNING at a point in the South side of Dorset Drive said point al,o being a distance of Six Hundred Ninety-rour and One One-Hundredths feet (694.01') West of the intersecOOn of the West side of Chippenham Road and the Soll1h side of Dorsel Drive, Ihence by !he 1in<: of Lot No, 148 South fony degr.., thirty-two minutes twenty seCOl1ds West (S 40 32' 20" W) a distance orOne Hundred Ninett'en and Seventy-Six One-Hundredths feet (119,76') to a point. in AT&T rigbt of way, at liD. of Lot No 166 Hampden Square Section 1,P1an Book 51, Page 2; thence by same and Lot No. 167 North fifty degrees fifteen minutes forty-two seconds West (N SO 15' 42" W) a distance of Ninety-Five and Fifty- Six One Hundredths felOt (95.56') to a point; thence by Lot No, 167 North siXiy-thr... degree' thlrteen minutes forty-five seconds We:.st (N 63 13' 45. W) a distance of Four and Ninety-Eigbt One Hundredtlis feet (4,98') to a point a line of Lot No. 146; thence by same NOM forty degrees thiny-two minutes twenty seconds East (N 4032' 20. E) a dL'tance of One Hundred Twenty-Two and Nineteen One- Hundredths feet (122,19') 10 a point on the South side of Dor.;et Drive; thence hy same South forty-nine desrees lwenty-seven minure.s forty ,ewoos East (S 49 27' 40" E} . distance of One Hundred feet (100.00) to the place of beginning. CONTAINING 12,008,30 square feet, known and numbered ... 3815 Dorset Drive. Mecbanicsburg, PA t7055. nn.!': TO SAID PREM1SES IS VES""'O IN R wi"- b D~-'.fr 1 ~ ~ obert A, Poorman and. Debora A Poorman hi. ", Y ..... 0lt1 ames R. Hegeman and La l' H . . . , . " recorded 4123/1998 ;" Record Book 175, Page 1l~6: . egel1llln, hIS WIre dated 4/22/1998 and Tax Parcel #1()-16-1056-IS4 4. Name and address oflast recorded holder of every mortgage ofrecord: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) FLEET MORTGAGE CORPORATION 1945 WEST PALMETTO STREET FLORENCE, SC 29501 WASHINGTON MUTUAL HOM LOAN INC. 11200 WEST PARKLAND AVENUE MILWAUKEE, WI 53224 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which rnay be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 3815 DORSET DRIVE MECHANICSBURG, PA 17055 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief, I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Julv 15. 2003 DATE J'1.J FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff IRWIN UNION BANK AND TRUST COMPANY CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS ROBERT A. POORMAN AfKIA ROBERT L. POORMAN DEBORA A. POORMAN CIVIL DIVISION NO. 03-2426- CIVIL TERM Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No, 1) IRWIN UNION BANK AND TRUST COMPANY, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,3815 DORSET DRIVE, MECHANICSBURG, P A 17055 . 1, Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) ROBERT A. POORMAN AlKlA ROBERT L. POORMAN 3815 DORSET DRIVE MECHANICSBURG, PA 17055 DEBORA A. POORMAN 3815 DORSET DRIVE MECHANICSBURG, PA 17055 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known 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 indicate) None IRWIN UNION BANK AND TRUST COMPANY Plaintiff, CUMBERLAND COUNTY v. No. 03-2426- CIVIL TERM ROBERT A. POORMAN AlK/A ROBERT L. POORMAN DEBORA A. POORMAN Defendant(s). July 15, 2003 TO: ROBERT A. POORMAN AIKIA ROBERT L. POORMAN 3815 DORSET DRIVE MECHANICSBURG, PA 17055 DEBORA A. POORMAN 3815 DORSET DRIVE MECHANICSBURG, P A 17055 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY" Your house (real estate) at, 3815 DORSET DRIVE, MECHANICSBURG, PA 17055, is scheduled to be sold at the Sheriffs Sale on DECEMBER 10, 2003 at 10:00 a.rn. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $94,280.27 obtained by IRWIN UNION BANK AND TRUST COMPANY (the mortgagee) against you. In the event the sale is continued, an armouncernent will be made at said sale in compliance with Pa.R.C,P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered, You may also ask the Court to postpone the sale for good cause, 3. You may also be able to stop the sale through other legal proceedings. 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 (215) 563-7000, 2. You may be able to petition the Court to set aside the sale ifthe bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390, 4. lfthe 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 may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are 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 TIIAT CERTAIN tract (or parcel of land and premi5eS, ~ilua<<:, lying and being in the TowlIShip of Hampclen in the CounlY of Cumberland and Ccmmonweatth of Pellllsylvaoia, more particularly described as follow.: BEING Lot #47, Kingswood. Pbase II, lIS recorded in Cumberland Coumy Plan Boole 55, Page 93, more particularly boWlded and de~cribed as follow., to wi\: BEGINNING at a point in the South side of Dorset Drive said poinl 0180 being a distance of Six Hundred Ninety-Four and One Qne.Hundredtbs feet (694.01') Wesl of the inters.etiem of the West side of Chippenham Road and the South side of Dorset Drive, Ihence by the line of Lot No. 148 South fony d.;grtes lhirty-two m!l1u!Cs twenty seconds West (S 40 32' 20" W) a distance of One Hundred Nincreen alld $Ilventy-Six One-Hundredths feet (119.76') to a palm in AT&T right of way, al1me of Lol No 166 Hampden SqI1llre Sccllon I, Plan Book 51. P8l!e 2; thence by SlUIle and Lol No. 167 North fifty d"ljJees fifteen minuleS fony-two seconds West (N 50 15' 42" W) a distance of Ninety-Five and flfty- Si" One HWldredths feI:t (95.56') to a point; thence by Lot No. 167 North sixty-three degrees thirteen minutes fOrty-fiVe second.\ West (N 63 13' 45" W) a distance of Four and Ninety-Eight One Hundredlhs feef. (4,98') 10 a point a line of Lot No. 146; thence by same North forty degrees thirty-two minuleS twenty second. East (N 40 32' 20. E) a dislMce ocf One Hundred Twenty-Two and Nineteon One- Hundredths feet (122,19') to Q pocittt on the $oulb side of Dorset Dri\'e; Ibence by,ame South forty-nine degrees twemy-seven minules forty second. East (s 49 27' 40" E) . distance of One Hundred feet (100.00) 10 the place of beginning, CONTAINING 12.008,30 square feet, known and numbered .., 3815 Dorset Drive. Mechllnicsburg, PA 17055, T~T~~ TO SAID PREMISES IS VESTED IN Roben A POtltrDan and Debo A P , Wlfu by Deed from James R. He eman and Laur,. .. . ra, OOlll'lan, IllS recorded 412~ll""8 'R d gal. Hegeman, hIS Wife dated 4/2211998 aDd J "" IJl eCor Boolt 175, Pase U)26. Tn.'!: Parcc:1 #10-16-1056-154 WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due IRWIN UNION BANK AND TRUST COMPANY, NO 03-2426 Civil CIVIL ACTION - LAW Plaintiff (s) From ROBERT A POORMAN AIKIA ROBERT L. POORMAN AND DEBORA A. POORMAN (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) nOllevied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the gamishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendanl (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject 10 attachmenl is found in the possession of anyone other than a named garnishee, you are directed to notify himlher thai helshe has been added as a garnishee and is enjoined as above stated, Amount Due $94,280.27 L.L. $.50 Interest FROM 7/15/03 TO 12/10/03 (PER DIEM - $15.50) Arty's Comm % Arty Paid $135.66 Plaintiff Paid Date: JULY 17, 2003 Due Prothy Other Costs - $2,294.00 AND COSTS $1.00 CURTIS R. LONG (Seal) Prothonot~ n ~ '-..!3y: L.d2n". fJ~C:. , '{r./l/kT. r--- Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPIDA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ill No. 12248 AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PIT PLAINTIFF IRWIN UNION BANK AND TRUST COMPANY No. 03-2426- CIVIL TERM DEFENDANT(S) ROBERT A. POORMAN AfKiA ROBERT L. POORMAN DEBORA A. POORMAN ACCT. #1172065 TYlle of Action _ Notice of Sheriff's Sale SERVE DEBORA A. POORMAN AT 3815 DORSET DRIVE MECHANlCSBURG, PA 17055 Sale Date: DECEMBER 10, 2003 \=<o\::e^ -\- f-\. \b;~ED \:X"~~~'" \- . l S"'~ t\-. Served and made known to ~ A"'(T' 1" ~..\ f'!, to!! I Q \) , npfPntl""t, on Ihe ~O day of .::rOL'i ,2001,at l\~30 ,0'clockA,m"at 3eP5 D~E:T' D~'~~ ,Commonwealth of Pennsylvania, in the manner described below: 'J.. Defendant personally served. 1 Adult family member with whom Defendant(s) reside(s). Relationship is ~ ,::, N S~'SO.N Adult in charge ofDefendant(s)'s residence who refused to give name or relationshlp. Manager/Clerk of place oflodging in which Defendant(s) reside(s), Agenl or person in charge of Defendant( s)' s office or usual place of business, an officer of said Defendant(s)'s company. Other> Description: Age ~ Height L Weight ~ Race vJ S"x A Other I, c.1-\ 11..\ S ff!.E IT ^'S , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at lJIlda J. JII1lP"'. NolaIY PUOI" Sworn 10 and subs~ed C8IIsIe Boro. QrnbefIand Coun~ before me lhis ~ day MyCoo,..;,,$ianElqlireoJ(jy23,2006 of /1t.J~~ (U./..-? Membef.PemS .lionOf~ J.-~ Nolary, rr- .~y: ~ ~~ PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED. NOT SERVED On the _ __ day of ,200_, al o'clock _.m., Defendant NOT FOUND because: Mf1ved Unknown No Answer Vacant 1 st Attempt: / / Time: 2nd Attempt: / / Time: 3rd Attempt: / / Time: Sworn to and subscribed before me this _ day of , 200 _' Notary: By: Attornev for Plaintiff Frank Federman, Esquire - LD. No. 12248 o c -:;"' "D['n rlln-, Z.~l:'1 tfj~ -- . .-='" <\..-., ;e:c ..c:.-< ""C) .....C Z =<! ..... c~ I....., C) "7-~ c:> " .-j I (...) ,') :-..;: :.::':'::.(--..01 .~~, ni ,) :p! XI -< N r:- -.J AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PJT PLAINTIFF IRWIN UNION BANK AND TRUST COMPANY No. 03-2426- CIVIL TERM DEFENDANT(S) ROBERT A. pooRMAN AfK/A ROBERT L. POORMAN DEBORA A. POORMAN ACCT. #1172065 Type of Action _ Notice of Sheriff's Sale SERVE ROBERT A. pooRMAN AfK/A ROBERT L. POORMAN AT Sale Date: DECEMBER 10, 2003 3815 DORSET DRIVE MECHANlCSBURG, P A 17055 ~{d ~""~ ~ ~.(~~ servedandmadeknownto~t.1T 'ft..!,t$QIP ,Bcfcudluil.onthe ;;~t dayof 3\)L'f ,2003- at \I'-~() ,o'clockft.m., at ~ ~ 15 DO~ 1)\2.. ~fCHA-N~~ Pk n050 ,Commonwealth of Pennsylvania, in the manner described below: Defendant persona\1y served. ~ 'J{ Adult family member with whom Defendant(s) reside(s). Relationship is ~ ~~:5<lC~ . Adult in charge ofDefendant(s)'s residence who refused 10 give name or relalio hip. Manager/Clerk of place oflodging in which Defendant( s) reside( s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company, Other> Description: Age .$ Height r.,f W eight ~ Race .'t:L- Sex ~ Other I, CHlZ.\) FP-e; ,TI\'::> ,a competenl adult, being duly sworn according to law, depose and state that I persona\1y handed a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the dale and at the address indicated above. Nola,..;' s;;;--- Sworn to and subscribed lJIldaJ,JlJJ1Illl1, Notary Pu1lIi, before me this ~day C8I1ISle~QrnbeI1anoCoun" of 1W~0(}3.. t.tteonmss;on . ~=ries Notary: . ~:J-~ y, n PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED. NOT SERVED On the __ day of ,200_, at o'clock _.m., Defendant NOT FOUND because: Moved _ Unknown _ No Answer Vacant 1 sl Attempt: I I Time: 2nd Attempt: I I Time: 3rd Attempt: I / Time: Sworn 10 and subscribed before me this _ day of , 200 _. Notary: By: Attornev for Plaintiff Frank Federman, Esquire - LD. No. 12248 o c: s:: ;:;?l G;, ~nl ~:::r:-r 6}r;" ...:<.::.; ~C '. zc::. j;;Cl c $ .." ::r ry .,.. -.J o Go o c., ...... I C.) ~"'-, ',0: :;; ::,'(') )' O'j', ::-;Jt~ (in1 0-< ~ -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA , IRWIN UNION jfANK AND TRUST ) CIVIL ACTION COMPANY ) VS. ) CIVIL DIVISION ROBERT A. P DORMAN AJKlA ) NO. 03-2426- CIVIL TERM ROBERT L. P bORMAN DEBORA A. OORMAN IAFFIDA VIT OF SERVICE PURSUANT TO RULE 3129 COMMON EALTH OF PENNSYLV ANIA COUNTY 0 CUMBERLAND ) ) SS: I, F NK FEDERMAN, ESQUIRE attorney for IRWIN UNION BANK AND TRUST C P ANY hereby verify that on Julv 17, 2003 true and correct copies of the Notice of S eriff s sale were served by certificate of mailing to the recorded lienholders, and any kn~ interested party see Exhibit "A" attached hereto, DATE:...N~vember 4. 2003 I I 1'JU't\ LW / 1~uwtn FRANK FEDERMAN, ESQUIRE Attoffii~y for Plaintiff '"0-; t"" 0>:.0: a' E """".. - '" 00 .... '" v. ... '" N :;. g>~a - z v. ... '" N - 0 " &:; = CD CD ",,"'.. [if CD '" = el' l> .. "" ~ g, ~ r .r co z c 3 cr CD ... "'0' ~ i!l ~ t;j (") " z ""-&?"rl ~" . g;~,,@ 2.- t71 ~ ~ ~ e [z . rr~if t71 t71 '" g, ;f ~ "' :I: ~ s: t71 > "'5 s: Z ~ '" .. ?=l .. gr"rl(") ~ 0 ;> 0 .:;J ii -~ R 0'"0 '" ,.., .~ . . " 9;;;" '"" d I:) t1l i:i ~~~~ g a 0 :z: (") > '" ~ > .,. ~ ~ &: ~ 0 ;~ :::j ~ \O?;aO t71 ~~ . o~g'J~ q = 0 ~ .. 8 c !' 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'0 _. -. - 5'~ g.~ 1 - = 5 s: e' iil ~'" i ~~p..\8) ";:t..'.~,)' " .~h ~" ~~ '!l {Il ii5 ~ . $ ~ li i'~. 3 . ~~~~,/~- ~&U'l5' i1iL:SR- ~~. ~~'!I;;'>~~~.~~ --83 ::r'ii _. ., . $ 01 5 i58:J )004301;,:"'''' ..~ 00 ~~1l ~ 1;"1"';llc::.0~rfl__I'iI_,{- il' Et;l'i~ 6 ~ 0' .. " 8 0 ~ <..) ;1::' % .-J -on:' c::> :L-n D;1rr <: ;""P -~' I "r..M Zl)c (TI 66 ~:;; i..J _,J ...> I.<.C -0 .c=+1 ::E:c ~ 1~:";O Zc ~ 0'" ::p. ... C -I ..-:. N ~ :2 CD '< Irwin Union Bank and Trust Company VS Robert A. Poorman aIkIa Robert L. Poorman and Debora A. Poorman In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-2426 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Frank Federman. Sheriffs Costs: Docketing Poundage Advertising Posting Handbills Levy Surcharge Service Postpone Sale Law Journal Patriot News Law Library Prothonotary Share of Bills 30.00 16.31 15.00 15.00 15.00 30.00 15.18 20.00 363.05 281.89 .50 1.00 28.90 $ 831. 83 paid by attorney 02/06/04 Sworn and subscribed to before me So Answers: This lf8:- day oCfd, r~~4'< "~ Ch / - . R. Thomas Kline, Sheriff 2004, A.D. A'. Q 111,d/;',-,,1#' J I BY Prothonotary Real E "sO eok l\t>~\, ~_ /<113 'If ~. 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 Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Ass!. 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 and..I!m... 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 regular dally and/or Sunday/ Metro editions which appeared on the 28th day(s) of October and the 4th and 11th day(s) of November 2003. That neither he nor said Company is interested in the subject matter of said printed notice or advertising. and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verity 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 Dauphin In Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY S ALE #20 ~~~::;~;;;~,o. \ NoIanalSaa! Ir:k ?r~ TalTY L. Russell, Notmy PullIic (. City Of Hanisoorg, Daup-nnCOUnly NOT RY PUBLIC My CommiSSion expires JlIle 6. 2006. M~ commission expires June 6, 2006 . Member. Pennsylvania Association Of Nolanes CUMBERlAND COUN1Y SHERIFFS OFFICE CUMBERlAND COUN1Y 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 Total $ 281.89 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.................................................................... " PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATEOFPENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Lisa Marie Coyne, 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 17, 24, 31, 2003 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. REAL ESTATE SALE NO. 20 Writ No. 2003-2426 Civil Irwin U niaD Bank and Trust Company v.. Debora A. Poorman and Robert A. Poorman, a/k/a Robert L. Poorman Atty.: Frank Federman ALL THAT CERTAIN tract or par~ eel of land and premises. situate. lying and being in the Township of Hampden in the County of Cumber- land and Commonwealth of Penn- sylvania. more particularly de- scribed as follows: BEING Lot #47. Kingswood. Phase II. as recorded in Cumber- land County Plan Book 55. Page 93. more particularly bounded and de- scribed as follows. to wit: BEGINNING at a point in the South side of Dorset Drive said point also being a distance of Six Hun- dred Ninety-Four and One One~Hun- dredths feet (694.01') West of the intersection of the West side of Chippenham Road and the South side of Dorset Drive. thence by the line of Lot No. 148 South forty de- grees thirty-two minutes twenty sec- onds West (S 40 32' 20" W) a dis- tance of One Hundred Nineteen and Seventy-Six One-Hundredths feet (119.76') to a point in AT&T right of way. at line of Lot No. 166 Hampden Square Section I. Plan Book 5l. Page 2; thence by same and Lot No. 167 North fifty degrees fifteen min- utes forty-two seconds West. (N 50 15' 42" W) a distance of Ninety-Five and Fifty-Six One Hundredths feet (95.56') to a point: thence by Lot No. 167 North sixty-three degrees thirteen minutes forty-five seconds West (N 63 13' 45" W) a distance of ,)tN- Marie COyne,~itor TO AND SUBSCRIBED before me this 31 day of OCTOBER. 2003 ~~~. A/rlU/dA/ ~'t~~oo. S~-' ,- LOIS E. SNYDER, Notary Public Carlisle BOlO. Cumbertand CountY My Commission Expires M8/dl5, 2005 scribed as foHows, to WI~. BEGINNING at a point in the South side of Dorset Drive said point also being a distance of Six Hun- dred Ninety-Four and One One~Hun- dredths feet (694.0 I') West of the intersection of the West side of ChippenhlliIl Road and the South side of Dorset Drive, thence by the line of Lot No, 148 South forty de- grees thirty-two minutes twenty sec- onds West (S 40 32' 20" W) a dis- tance of One Hundred Nineteen and Seventy-Six One-Hundredths feet (119.76') to a point in AT&T right of way, at line of Lot No, 166 Hampden Square Section 1, Plan Book 51, Page 2: thence by same and Lot No, 167 North fIfty degrees ftfteen min- utes forty-two seconds West. (N 50 15' 42" W) a distance of Ninety-Five and Fifty-Six One Hundredths feet (95.56') to a point: thence by Lot No. 167 North sixty-three degrees .... thirteen minutes forty-five seconds West (N 63 13' 45" W] a distance of rour and Ninety-Eight One Hun- dredths feet 14.98') to a point a line of Lot No, 146; thence by same North forty degrees thirty-two min- utes, twenty seconds East (N 40 32' 20" E) a distance of One Hundred Twenty-Two and Nineteen One~ Hundredths feet (122. 19'} to a point on the South side of Dorset Drive; thence by same South forty-nine degrees twenty-seven minutes forty seconds East IS 49 27' 40" E.} a distance of One Hundred feet (100.001 to the place of beginning. CONTAINiNG 12.008.30 square feet. known and numbered as 3815 Dorset Drive, Mechantcsburg, PA 17055. TITLE TO SAID PREMISES IS VESTED IN Robert A, Poorman and Debora A. Poorman, his wife by Deed from James R. Hegeman and Laura T. Hegeman. his wife dated 4/22/1998 and recorded 4/23/ 1998 in Record Book 175, Page 1026. Tax Parcel H 10~ 16~ 1056~ 154. AFFIDAVIT OF SERVICE PLAINTIFF IRWIN UNION BANK AND TRUST COMPANY CUMBERLAND COUNTY KMD No. 03-2426 C.T. DEFENDANT(S) ROBERT A. POORMAN, AlK/A ROBERT L. POORMAN ACCT. #1172065 SERVE ROBERT A. POORMAN, AlK/A ROBERT L. POORMAN Type of Action - Notice of Sheriff's Sale AT Sale Date: JUNE 8, 2005 Served and made known to Rr)h~f~. I 3815 DORSET DRIVE MECHANICSBURG, PA 17055 SERVED ~r~~~tJ.Defendant,ontbe !3rJl, day~;Mk~ .2005 0,"-5(0'- 0,<.,; IJ~.<)t-JiC5I.o\J,cj ,Commonwealth at ~: J 8. o'clock -fm., at .3 '8/ 6" of Pennsylvania, in the manner described below: Defendant personally served. =%=AdUIt family member with whom Defendant(s) reside(s). Name and Relationship is Adult in charge of Defendant(s)'s residence wbo refused to give name or relationship. Manager/Clerk of place oflodging in wbicb Defendant(s) reside(s). Agent or person in charge ofDefendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: _ I I _ - /vc, '3 ~J-S.SC S Description: Age~ Height~ Weight I~'J Race U)LtsexE Other blo /..J d &V3-; vZ I, -.e12l<<.('1J c ( L I Gvz:+t, i'~etent adult, being duly sworn according to law. depose and state that 1 personally handed a true and correct copy of the Notice' of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. W"f~ . o ~60R. -a -A, foe f( tA.1 d tJ Sworn to and subscribed before me this 1[+11 dll)' ~ of rnve LA.. . 200~~ .. ! . Notary:'J}ccc.iC_ fl{u:~~ By. I a PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES NOTARIAl. SEAL LUelle H. CARTY, = PubIc ~~Nov.1M F SERVICE ATTEMPTED. NOT SERVED Dnthe day of ,200_, at o'clock _.m., Defendant NOT FOUND because: Moved ~ Unknown _ No Answer Vacant 1st Attempt: 3rd Attempt: / / Time: 2nd Attempt: / / Time: / / Time: Sworn to and subscribed before me this ~ day of , 200 _ Notary: By: Attornev for Plaintiff Daniel G. Schmieg, Esquire - J.D. No. 62205 f'! ,... .~ , -~..~._~. 1 '::'~~~~~~:e '::~-=:1i~~'~::k,-""R;;;::;D~~e~;~~'~~~;"'.'1~'::1k~:~;;i"':J;1;~;~t~,.," ,200.fat 5': f B'O'c1ockf..m.,at :38/5' X>>ft.SC't- OJ(., ) .MC.C~f{l'~ ICS/oUKJ , Commonwealth of Pennsylvania, in the manner described below: X Defendant personally served. Adult family member with wbom Defeodant(s) reside(s). Name and Relationship is Adult io charge ofDefendanl(s)'s residence who refused to give name or relationship. Manager/Clerk of place oflodging in which Defendant(s) reside(s). Agent or person in charge ofDefendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Age.!h2 Height !;-f' Weight !JS Race LJ~ sexL Other iV, 'j ~s~:~~ C'. ,j f2,1 ~ j:)\P10C1 I, d(t.f' ~Ct.. 1-.1 L::Jrt" , a competent adult, being duly sworn according to law, depose and stale that [ personally handed a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Descri tion: L NOTARIAL SEAl. Sworn to and subscribed ~ =IU.E H. CARTY, NolIry NlIc ~;f;':;~~t~~'~~)2~~:X ~. . ( j/Z ? ? r j ~~ ~ ~~~~ Notary: cUtz... Uf.lvc By: :{ t7'C-62.t PL~E ATTEMPT SERVICJ AT LEAST 3 TIMES. INDICATE DA T~ ES OF SERVICE ATTEMPTED. NOT SERVED On the day of ,200--, at o'clock ~.m., Defendant NOT FOUND because: Moved Unknown No Answer Vacant 1" Attempt: / / Time: 2nd Attempt: / / Time: 3rd Attempt: / / Time: Sworn to and subscribed before me this ~ day of ,. 200 _' Notary: By: Attornev for Plaintiff Daniel G. Schmieg, Esquire, l.D. No. 62205 AFFIDAVIT OF SERVICE PLAINTIFF IRWIN UNION BANK AND TRUST COMPANY CUMBERLAND COUNTY KMD No. 03-2426 C.T. DEFENDANT(S) ROBERT A. POORMAN, AlKJA ROBERT L. POORMAN ACCT. #1172065 SERVE ROBERT A. POORMAN, AlKJA ROBERT L. POORMAN Type of Action - Notice of Sheriff's Sale AT Sale Date: JUNE 8, 2005 Served and made known to.fl()h~~l, at ~: J 8 . o'clock -fm., at 3 '81 6 3815 DORSET DRIVE MECHANICSBURG, PA 17055 SERVED '~f~\\,~jJ. Defendant, on the "!3t1-l day;~71kd" . 2005 Cb~s<;:t 0((,) tl",.ck'Jt-J iC5/uv K3 .Commonwealth of Pennsylvania, in the manner described below: Defendant personally served. $Adult family member with whom Defendant(s) reside(s). Name and Relationship is Adult in charge of Defeodant(s)'s residence who refused to give name or relationship. Manager/Clerk of place oflodging in which Defendant(s) reside(s). Agent or person in cbarge ofDefendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. ~ ~, k I I . {VC, ":; J-SSC S Description: Age.!/!2 Height-.E!f WeightQIJ Race 1JLtsexL Other blo /oJ d !A.'",; ~ I, -.eldl'LtiJC I: 1-- J G~+/, li'~etent adult, being duly sworn according to law, depose and state that I personally haoded a true and correct copy of the Notice'ofSheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. W'If-~ . O~bOKd A. foe fZ Kid tJ Sworn to and subscribed beforemethisi-f+hdaX &. _ (' of f)'JJ-l-<-1\ . 200~~ ..' .I , Notary: '-I L llC7,j~.lJ By: ~:I~ ~tC'Li- ~-- / ) . c PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES NOTARIAL SEAL LUCIUE H. CARTY'::In PubIc ~~Nov.1M F SERVICE ATTEMPTED. NOT SERVED On the day of ,200_, at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer Vacant 1" Attempt: / / Time: 2nd Attempt: / / Time: 3rd Attempt: / / Time: Sworn to and subscribed before me this ~ day of .,200 _ Notary: By: Attornev for Plaintiff Daniel G. Schmieg, Esquire - 1.0. No. 62205 ,... ^ ~ -- - --- , AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PLAINTIFF IRWIN UNION BANK AND TRUST COMPANY PJT No. 03.2426 C.T. DEFENDANT(S) DEBORA A. POORMAN DEBORA A. POORMAN ACCT. #1172065 SERVE AT DEBORA A. POORMAN Type of Action . Notice of Sheriff's Sale . 3815 DORSET DRIVE MECHANICSBURG, PA 17055 ... ... .......................... ... ......._".~..~-~............~..... ..... ...... SERVED . .....;..,..............'ir-'-...~,........ .o........,..c........,.. ,...~~~~..;;;~..~e known to~~.yt:9:" A/ f2~f(~\0..t!D~f~d~~.~~d,t.'..i~.....'#l~''J;.;~r..J;f,~j(t~bi ,2oo.:fat 5: (B.O'c1ockt.m.,at :38/S JJ;.rtsef- OJ\:. I ) .M\:,C~j&"-'iC5La\)KS Sale Date: JUNE 8, 2005 , Commonwealth of Pennsylvania, in the manner described below: X Defendant personally served. Adult family member with whom Defendant(s) reside(s). Name and Relationship is Adult in charge ofDefendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place oflodging in which Defendant(s) reside(s). Agent or person in charge ofDefendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: I I . fJ cJ \ta.SST< S Descri tion: Age.fit2 Height j,-If Weight j;.s- Race LtJ~ SexL Other . (" I \ .. K. .. . .. I ().I ~ lCl 010 Q '^~ \ I, C;) tZ-e /0c ~ /-..1 L;Jyt,\ , a competent adult. being duly sworn according to law, depose and state that [ personally handed a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. NOTARlAL <>1:&1 LUCILLE """'- Sworn to and subscribed ~ .. I.eIWkennv ~lMCARTY, = PubIc beforem~this.13+-hda~. .r) !I<((i~ My~~~1~ ofl'n~ L~''--.200-,-~ 'W; " M.. A .' , . -. t [ .. ~/? .,) , , Notary: cJt'.L. - V<- By: ..1(- .A-' PLdsE ATTEMPT SERVIC~ AT LEAST 3 TIMES. INDICATE DA T:;J:r ES OF SERVICE ATTEMPTED. NOT SERVED On the day of ,200_. at __ o'clock _.m.. Defendant NOT FOUND because: Moved Unknown No Answer Vacant 1" Attempt: / / Time: 2nd Attempt: / / Time: 3rd Attempt: / / Time: Sworn to and subscribed before me this _ day of .200 Notary: By: Attornev for Plaintiff Daniel G. Schmieg, Esquire. I.D. No. 62205 ~~ PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3I83 IRWIN UNION BANK AND TRUST COMPANY Plaintiff, v. No. 03-2426 C.T. ROBERT A. POORMAN, A/KJA ROBERT L. POORMAN DEBORA A. POORMAN Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of executijin the above matter: Amount Due \~ :1\\ ..J Interest from to JUNE 8, 2005 (per diem -$15.50) $94,280.27 $10,726.00 and Costs TOTAL $105,006.27 /~) DANIEL G. SCHMIEG, ESQU One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property. No. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. '-? R ~ ~ ~~ ~ ~ ~ 7- \<o>z 0 ~ o~ ~ 'Q?: ~ ,j C ~~ ~ ~~ ~~ ~rf1 7-7- I-" ~~ Iiila ~ o~ ~ ~o (.-;:, ~~ o " .. ~ ~ ..... ~o ~a o~ ~~ .;. ~~ r,,)7- ~~ ... ~ ~~ ~S ;c~ ~~ ~~ r,,) ~e o<C ~~ (.-Q % ~~ Iiilb S~ O~ 0 ~~ ~ 0 ~ ~ 'P% e ~ ~ ~ ~~ r,,) ~ ~ "~." . ...0 C" "', ,x , f? UJ':.c< ~I: ;~~.:' P' '/,--)r~~, - - - '" - "';. ?:,?/. ('; - - I a~ c>.::..\\J.- c'- ;: ~;:;~l1J .1...'- - ::: .::. w-:c o'I:::t: ::: - - ';.s:. - \.... ~ d tJ...- LJ"-:'/ (::;;':~ , C) c..::} <~ \ \ I I () ..Jl J C'<) 0 :} G c;- O ..s () 'C>.. L1 () <:\ 0- l.1l t:- ..Jl - ~ (J In c:r - 0) CV) ~ 'l;'- ~ - ~ ()- -~ LEGAL DESCRIPTION ALL THAT CERTAIN uact or parcel of land and premises, situat~, lying and being in the TowllIlhip . of Hampden in the County of CumOOrI3Ild and Commonweahh of PeDmylvania. more particlllarl}' described as follows: BEING Lot 1147, Kingswood, ?base II, as recordw in Cumb<:rland Coullty Plan Book 55, rage 93, more particularly ooWlded and Je..;I,Tibed as follows, to wit: HEGlNNING at a point in thc South side of Dorset Drive said r<Jint also bcing: a distance of Six Hundred Ninety-four and One Onc-HUlldredtl1s feet (694.01') West of the il\lcrsection of the West SIde of Chippenham Road and the South side of Dorset Drive, thence by !he line of Lot No. 148 South forty degr~s thiny-tWo minutes twenty seconds West (5 40 32' 20" W) a distance of One Hundred Nineteen and Seventy-Six One-Hundredths feet (119.76') to a point in AT&T righl of way, at line of Lot No. 166 Hampden $quare Section 1. Plan Book 51. Page 2: thenc<: by same and Lot No. 167 North fifty degrees titteen minutes forty-two seconds West (N 5(J 15' 42' W) a distance of Ninety-Five and Fifty Six One Hundredths feet (95.56') to a point; rhence by Lot No. \67 North sixty.three degrees tl:rirteen minnres forty./'jve seconds West (~ 63 13' 4S' W) a diuance of Four and Ninety.EJght One Hundredths '<!et (4.98') to a point a line of Lot N<l. 146; Ihence by same Notlh fort)' degreeS thitty-two minutes twl:lllY se;;onds East (N 40 32' 20. E) a distance of o~ Hundred Tv.'enty- Two and Nineteen One- Hundredtbs feet (122.19') to a poim on the South side of Dorset Drive; thencc by samc South forty-nine degrees twenty-seven minutcs forty seconds East (S 49 27' 40" E) a llistance of O~ Hundred feet (100.00) to the place of beginning. CONTAINING 12,008.30 square feet, kllown and numbered a~ 38\5 Dorset DriVe, Mechanicsburg, PA 17055 TITLE TO SAID PRE!\:!ISES IS VESTED IN Robert wife by Deed from James R Hegema and L ,A. Poorma,n a~ Debora A. POQlmSll, his re.:orded 4/23/1998' Re 'd D__ n aura 1. Hegeman, hIS Wife dated 4/2211998 and In cor avvk 115, Page 1026. TAX PARCEL # 10-16-1056.154 PREMISES BEING: 3815 DORSET DRIVE, MECHANICSBURG, P A 17055 WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-2426 Civil CIVIL ACTION ~ LAW TO THE SHERlFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due IRWIN UNION BANK AND TRUST COMPANY, Plaintiff (s) From ROBERT A. POORMAN, AlKJA ROBERT L. POORMAN, DEBORA A. POORMAN (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to 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 of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property 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 garnishee and is enjoined as above stated. Amount Due $94,280.27 L.L. Interest FROM 7/17/03 TO 6/8/05 (PER DIEM - $15.50 - $10,726.00 AND COSTS Atty's Corom % Due Prothy $1.00 Atty Paid $979.99 Other Costs Plaintiff Paid Date: MARCH 3, 2005 CURTIS R. LONG (Seal) Prothonotary -llY a 0-,,, f;l !f-VJA.;- Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION t617 JOHN F. KENNEDY BOULEV AR'D, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 62205 IRWIN UNION BANK AND TRUST COMPANY . CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS ROBERT A. POORMAN, AlKJA ROBERT L. POORMAN DEBORA A. POORMAN CIVIL DIVISION NO. 03-2426 C.T. Defendant(s). AFFlDA VIT PURSUANT TO RULE 3129 (Affidavit No. I) IRWIN UNION BANK AND TRUST COMPANY, Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, 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 ,3815 DORSET DRIVE, MECHANICSBURG, P A 17055 . 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) ROBERT A. POORMAN, A/KJA ROBERT L. POORMAN 3815 DORSET DRIVE MECHANICSBURG, P A 17055 DEBORA A. POORMAN 3815 DORSET DRIVE MECHANICSBURG, PA 17055 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known 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 indicate) WASHINGTON MUTUAL BANK FA PO BOX 1169, DEPT. 2665 MILWAUKEE, WI 53201 - 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) FLEET MORTGAGE CORPORATION 1945 WEST PALMETTO STREET FLORENCE. SC 29501 11200 WEST PARKLAND AVENUE MIL W AUKEE, WI 53224 WASHINGTON MUTUAL HOME LOANS. INC. 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 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: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 3815 DORSET DRIVE MECHANICSBURG, P A 17055 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. March 2, 2005 DATE DANIEL G. SCHMIEG, ES Attorney for Plaintiff RE i-j-I n , . '" ':::::""> ,-;::.- (.n -- ..":,~. :;;'1:) \ <..) i;:: (",,) _J PHELAN HALLINAN AND SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF IRWIN UNION BANK AND TRUST COMPANY Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION ROBERT A. POORMAN, A/KlA ROBERT L. POORMAN DEBORA A, POORMAN NO. 03-2426 C.T. Defendant(s). CERTIFICATION DANIEL G. SCHMIEG, 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: o an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. (v---<~{~ DANIEL G. SC MIEG, UIRE Attorney for Plaintiff 2::; C) I:;;::~ ~"n ..:.;"'1 -- ..-l\,,. :;~:.\'> :;'0 I (...) '2 v:J -' ~ IRWIN UNION BANK AND TRUST COMPANY Plaintiff, CUMBERLAND COUNTY v. No. 03-2426 C.T. ROBERT A. POORMAN, A/KJA ROBERT L. POORMAN DEBORA A. POORMAN Defendant(s). March 2, 2005 TO: ROBERT A. POORMAN, AfKJA ROBERT L. POORMAN 3815 DORSET DRIVE MECHANICSBURG, P A 17055 DEBORA A. POORMAN 3815 DORSET DRIVE MECHANICSBURG, P A 17055 **THIS FIRM IS A DEBT COLLECTOR A TTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN A TTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY ** Your house (real estate) at , 3815 DORSET DRIVE. MECHANICSBURG. P A 17055, is scheduled to be sold at the Sheriffs Sale on JUNE 8. 2005 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $94.280.27 obtained by IRWIN UNION BANK AND TRUST COMPANY (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. 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 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. 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 is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. Ifthe 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 may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are 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. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL TIgT CER1AIN tract or parcel of land and premises, situate, tying and being in the Township. of Hampden ill the County of Cumberland and Commonwealth of Pennsylvania, more panicularly ue.~cribeu as follows: BEING Lot #47, Kingswood. Phll.'IC II, as recorutu in Cumberland County Plan Book 55. Page 93, more particularly ooUllded and describtd as funow.~. 10 wit BEGtNNING at a point in the Sonth side of Dorset Drive said point also being a distance of Six Hundred Ninety.Four and One Ono-HUlldredths feet (694.01 ') West of lhe inlcrsecti<)n of tile West SIde of Chippenham Road and the South side of Dorset Drive, thence by the line ofLol No. 148 Sm.1h forty degrtes thilty-two minutes lwenty seconds West (5 40 32' 20" W) a disunce of One Hundred Nineteen and Seventy-Sill One-Hundredths feet (119.76') to a poil![ in AT&T rigbt of W'dY, allint of LtIt Nu. 166 Hampden Square Section 1. Plan Book Sl. Page 2; lhen<:e by same and Lot No. 167 North fifty degrees fitreen minutes fony-two seconds West (N SO 15' 42" W) a distance of Ninety-Five and Fifty- Sill One Hundredths feet (95.56') to a point; thence by Lot No. 167 North sixt)..-tbree degrees thiIteen minute~ forry.five seeoods West (N 63 13' 45" W) a dista.oce of Four and Ninety-Eglu One Hundredths feel (4.98') to a poinl a line of Lot No. 1~; thence by same Notl:ll forty degrees thirty-cwo minutes twenty s<xonds East (N 40 32' 20' E) a diStance of One Hundred Twenty-Two and Nineteen One- Hundredtbs feet (122.19') to a point on the Soulll side of Dorset Drive: thence by same South forty.nine degrees twenty-seven minutes forty seconds East (S 49 27' 40" E) a distance of One Hundred feet (100.00) to the place of beginning. CONTAfNING 12,008.30 .square feet, known and numbered a.~ 3815 Dorset Drive. Mechanicsburg, PA 17055. ;:J;; T~~A~~~.El!;fISES [~VESTED IN Ro~ A. Poorma.n and Debora A. POOffilal\. his , Y .ames R. Hegeman and laura 1. Hegeman, hIS WIfe daled 4/2211998 and recordC(j 4/23/1998 111 Record Book 175, Page 1026. TAX PARCEL # 10-16-1056-154 PREMISES BEING: 3815 DORSET DRIVE, MECHANICSBURG, PA 17055 o -n I L.) s~'j (;) L"' _J - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA -- IRWIN UNION BANK AND TRUST COMPANY ) CIVIL ACTION ) vs. ROBERT A. POORMAN, AJKJA ROBERT L. POORMAN DEBORA A. POORMAN ) CIVIL DIVISION ) NO. 03-2426 C.T. AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLV ANIA COUNTY OF CUMBERLAND ) ) SS: I, DANIEL SCHMIEG, ESQUIRE attorney for IRWIN UNION BANK AND TRUST COMPANY hereby verify that on March 8. 2005 true and correct copies of the Notice of Sheriffs sale were served by certificate of mailing to the recorded lienholders, and any koown interested party see Exhibit "A" attached hereto. DATE: May 1 L 2005 DANIEL G. SCHMIEG, ES IRE Attorney for Plaintiff IRWIN UNION BANK AND TRUST COMPANY - ClIMBERLAND COUNTY Plaintiff, v. COtJRT OF COMMON PLEAS ROB~:RT A. POORMAN, A/KJA ROBEHT J.. POORMAN DEBORA A. POORMAN CIVIL DIVISION NO. 03-2426 C.T. Defendant(s). AFFIDA VIT PURSUANT TO RULE 3129 (Affidavit No. I) IRWIN UNION BANK AND TRUST COMPANY, Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following infonnation concerning the real property located at ,38] 5 DORSET DRIVE, MECHANICSBURG. P A 17055 . I. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained. please indicate) ROBERT A. POORMAN, AlKfA ROBERT L. POORMAN 3815 DORSET DRIVE MECHANICSBURG, PA 17055 DEBORA A. POORMAN 3815 DORSET DRIVE MECHANICS BURG, PA 17055 2. Name and address ofDefendant(s) in the judgment; Same as above ~~,*,;,::~'.~;::~--.; "^-:;.;;-_. ~.~~_;''''~'l-.V''~~lf'~'''''' '~"";;;''''''''Y''_''~''_n ,"_h''''~''''''''''__''_ ."--"'''''''0'''' .,.:.;.~_"":-\"..:,.,,..t'''"'_' "'Y"'-'-'i'+>,-""~:',H",-,"'. '1P..'3~''lIJm1t= Tr-~1t_11.~rlll:.'twl'.11iI1H ",~".';",,~'1j!j'~ 'Af'-"-d~'I-r-rmllt;. '. ,'.' :','. .. ame an as own a ess 0 every JU gmen ere I or ose Juugmen IS a reco~ len on me rea '. . . .' ~~-:p~(:)p€:rty:{o- be -SOla~1~~~'l.1it~~_~;,,,',~~"f~i~~;~~~~'1,;;~~~j11::1~;k':ktr$;;'-~::~Y*'0~1'-itj~l'fhrt:&<;':~:t"(~~~}7';:F;-:/~*~1)1~rt,~"j_?;t'~~'~4~~ ~r:~~~r""rI_L.{}j~_~_;-'rtr~r'.~r~-'i~i-ldi'i~~~Ju~}::i~t~~~,l~'lI~~'I'~~~~t_-~!'~~_-'~~~~:~~~~lr;f~kkl~~'fi"-iM<:~'r;.ir,t'#~~~~';;:M~~~.-l%~Xf~'"~"'-:tit'-f!H'U1fj' Last Known Address (if address cannot reasonably ascertained, please indicate) WASHINGTON MUTUAL BANK FA PO BOX 1169, DEPT. 2665 MILWAUKEE. WI 53201 4. N.ame and addrcss of last rccorded holder of every mortgage of record: Name Last Known Address (if address cannot he reasonably ascertained, please indicate) FLEET MORTGAGE CORPORATION 1945 WEST PALMETTO STREET FLORENCE, SC 29501 WASHINGTON MUTUAL HOME LOANS. INC 11200 WEST PARKLAND AVENUE MILWAUKEE, WI 53224 5. Name and address of cvcry other pcrson who has any record lien on the property: Name Last Known Addrcss (if address cannot be reasonably ascertained, pleasc indicate) None 6. Name and address of every othcr person who has any rccord intcrest in the property and whose interest may be atrected by the sale. Name Last Known Address (if address cannot bc reasonably ascertained, please indicate) None 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: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 3815 DORSET DRIVE MECHANICS BURG, PA 17055 :"'.~"~ pomeStic ~eIations, of <:;tiinberla~d .(:ount}:," 13 N:orth Hano~r Street ",' " . .lI1gl'l~Uilr~:~1l!UU !,\l!ll'l!~I. m "1M,t~ I ~n!lU!ji,!!\I~J!II!JllIlt ,Ili:'i" cfr!ii;I:;"~013 ""0!II~lltl.,~~~!II"0,R~"I'!~~J,~~!LjJ1~!\k"!.~" .r." f,~Y.a.-.,.l,;;;{if!~_;1:~J,J.<,fI,_Jtr;,~s:1-t;~;W~:ff.~~~t~:1j:t't~:;:t'k:'if'i'~'~~';~:'?"~i';\!;:o.:'/":t::t:-~-~{~;~m'4Wf:,fr;:ft::i:-~t.m~'t:'"'~;'?<:",,:::'N:~?y.\'::_~-tr.tt,~'/:1:"-': .-~r0:,;f~~:;'\:':;k"~f'_:;<~,e::;;f:':':'?1~~ Commonwealth ofPenllsylvania PO Box 2675 T~::::-':"'f"'Depa..-nnentof,Welfare~~,...:;'1'"ili'''.:Uif$i(I'' Harrisburg, PA .17105~-""""i,,(..N'~I"""~_lIi~ ;;:'j~'of:~~,';,~_':,~2:'~_; ::-:;:E~_'fi7d;',~~,;,-,;~:: ~9:~~~:::-&;4i~t:;~j:~~;.~~:~:;i::;:;::'':;:;I;;:X:::'S;,_:~,.;:t:+',;;:~;~,<;;;:,:,:'~~;;,;'~:X2:;";;:",'i,_::~,j0c'-:::-,;7~-:-;:-::;}jti,,, ~~_~';.:';,,;,;2;.~g:s;"~':;;~:c'::ic_:-::;' :f;' - "::;;\:~,::.~::~::'~' ,.e that statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C.s. Sec. 4904 relating to unsworn falsification to authorities. March 2. 2005 DATE cZ1-' . /-D~ DANIEL G. SCHMIEG, ES Attorney for Plaintiff ..... oO"'; ~~ .-1. c-= 'A% ~~ ,~~ if' \: - v- - .t> - v' ~ w, ~ )> "" o \ 'f ~ 'Q )> ~ tP ';\ .-\ ,.. '" s \ ",..; ~ 0 .",~ >7 j;.< ~~ oO- ~ 0 '0:9- 'S'\~ 't1. ~ ",oO .%~ -3:. ." ~~ oO . 9- ~ 9, " ~ ~ , ;? - N ..... - - o -.0 ~""'G&'t g',f\e,~ ~ -v>~~ 2 ~ ~<" 0 s ~ "''6~~(> ~"I>A ~-<;!. ~ 0<'9' ~o-~ ~~ ~~ g ';:.~-'C.-;g., g'~pg;' ;:c:~,;:) (\' ~ ~ 'e,g~... %:~~t~ ? ~ ~ ~~. ~('D- s..1O~~~ ~ ;;;-~ % g',-> ;,'(l~,~~ ..-J T","O';>C: :5- . c... ~ ~ ~% ~%:. '"" ~,\2 0 ';_%"9.~ ~ 91$; $' .... -. 5 ~~~'a S%~'" ?a~fi 'G~%~ ~8 "" (\> :;:.,&S'.<B ~~~~ ~gg2. ;;\f~ · "€>~(>'b 'i'~ g' ~ ~ ~ .. ~~H !"%~3 ~ g.~. % Cl~</l- %~~~ ; ;"8% nOs. ?d. -,::~ goO ~t:>~~ '7'<:'> ....~ ~",-'9.,'i> %. S 9: \ .: \ :1" 1 ~ ao --' '" v- .t> '" C N - ~ ,.. -a. ~ .. 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(-..,) c::::. ~ <;",,1"1 C) '-,1 -j ;ri ;:l? .-,--,1 ---..:; rv C:.' ~; [-l'1 " f'.. :11 < CJ Irwin Union Bank and Trust Company VS Robert A. Poorman, a1k/a Robert L. Poorman and Debora A. Poorman In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-2426 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Daniel Schmieg. Sheriff's Costs: Docketing Poundage Posting Handbills Advertising Law Library Prothonotary Mileage Certified Mail Levy Surcharge Postpone Sale Law Journal Patriot News Share of Bills 30.00 17.56 15.00 15.00 1.00 9.62 2.14 15.00 30.00 20.00 377.00 346.69 16.47 $ 895.48 Sworn and subscribed to before me prothonotarf- So Answers: .~~ : -..~ /~""f' R. Thomas Kline, Sheriff BY \ l6CiqJvv0l ~ Real Estate Sergeant 't.<J<J CI<. 'n D rf ~ jlSL 7{ IRWIN UNION BANK AND TRUST COMPANY , CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS ROBERT A. POORMAN, A/KIA ROBERT L. POORMAN DEBORA A. POORMAN CIVIL DIVISION NO. 03-2426 C.T. Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) IRWIN UNION BANK AND TRUST COMPANY, Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, 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 ,3815 DORSET DRIVE, MECHANICSBURG, P A 17055 . I. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) ROBERT A. POORMAN, AlK/A ROBERT L. POORMAN 3815 DORSET DRIVE MECHANICSBURG, PA 17055 DEBORA A. POORMAN 3815 DORSET DRIVE MECHANICSBURG, PA 17055 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment isa record lien on the real" property to be sold: .. . Name Last Known Address (if address cannot be reasonably ascertained, please indicate) WASHINGTON MUTUAL BANK FA PO BOX 1169. DEPT. 2665 MILWAUKEE. WI 53201 4. Namc and address of last rccorded holder of every mortgage of rccord: Name Last Known Addrcss (if address cannot he reasonably ascertained, please indicate) FLEET MORTGAGE CORPORATION 1945 WEST PALMETTO STREET FLORENCE, SC 29501 WASHINGTON MUTUAL HOME LOANS,INC. 11200 WEST PARKLAND AVENUE MILWAUKEE, WI 53224 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 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: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 3815 DORSET DRIVE MECHANICSBURG, PA 17055 Domestic Relations of Cumberland County , '"'~'..il"'~'H''''''' 13 North Hanover Street Carlisle, PA 17013" Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verifY that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. March 2, 2005 DATE <L:J. F ~ DANIEL G. SCHMIEG, ES~ Attorney for Plaintiff , IRWIN UNION BANK AND TRUST COMPANY Plaintiff, ClJMBERLAND COUNTY v. No. 03-2426 C.T. ROBERT A. POORMAN, AJK/A ROBERT L. POORMAN DEBORA A. POORMAN Defendant(s). March 2, 2005 TO: ROBERT A. POORMAN, A/KJA ROBERT L. POORMAN 3815 DORSET DRIVE MECHANICSBURG, PA 17055 DEBORA A. POORMAN 3815 DORSET DRIVE MECHANICSBlIRG, PA 17055 * * 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 /N BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS /S NOT AND SHOULD NOT BE CONSTRUED TO BE AN A7TEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY" Your house (real estate) at, 3815 DORSET DRIVE, MECHANICSBURG, PA 17055, is scheduled to be sold at the Sheriffs Sale on JUNE 8, 2005 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $94,280.27 obtained by IRWIN UNION BANK AND TRUST COMPANY (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT TIllS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. Thc sooner you contact one. thc morc chancc you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the propcrty until the full amount duc is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are 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. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN traet or parcel of bod aod premises, situate. lying and being Ul the l"ownsl1i? of Hampden in the Coumy of Cumberland and Commonwealth of Pennsvl\'unia, more paTiicuJarly de'cribe<.l "" foUmvs: BEING Lot #47, Kingswood, Pbase II, as reconlto in Cumberland Coumy Plan Bool: 55. Page 93, more particularly bounded and oe:;cribeU as follows. to wit: BEGINNING at a point in the South side of Don.et Drive said point also being a distance of Six H\lndreJ Ninety-I.our and One One-Hundredths feet (694.01') WesT of the intersection of the West side of Chippenham Road and the South side of Dorset Drive, thence by dIe line of Lot No. 148 South fony degrees thirty-two minutes twen.ty seconds West (S 4032' 20" W) a distance of One Hundred Nineteen and Seventy-Six One-Huntlredths feet 019.76') to a point in AT&T right of way, at line of Lot No. 166 HampoclI Square Section 1. Plan Bool< 51. Pag" 2; thence 11) same and Lot No. J67 C;orth fifty degrees fifteen minutes forty-two seconds West (N 50 15' 42" W) a distance of Ninety-Five and Fifty- Six One HutKlredths feet (95.56') to a point; thence by LOl No. 167 North sixty-three degrees thirteen minutes forry-five seconds West (N 63 13' 45" V{) a distance of Four aIKl Ninety.8ght One Hundredths feel (4.98') to " pobl 3 li.ne of Lot No. 146. Iher,ce by same North forty degreeS thirty-two mindtes twenty s<'Cvnds East (N 4032' 20" E) a disunce of One Hundred Twenty-Two and Nineteen One- Hundredths feet (122.19') to a point on the South side of Dorset Drive; thence by same South lorty-nine degrees twenty-seven minu~ forty seconds East (S 49 27' 40" E) a distance of One HLlIldred feet (100.00) to the place of beginning. CONTAlNlNG 12.008.30 square feet, known and numbered .., 381:5 Dorset Drive, Mechanicsburg, PA 17055 TITI.E TO SAID PREMISES rs VESTED IN R wife b Deed f obert A. Poorman and Debora A. Poormall, his recork 4/23/:::: ~ ~~5and LallOll'. Hegeman, his wife daled 4/22/1998 and , Page 1026. TAX PARCEL # 10-16-1056-154 PREMISES BEING: 3815 DORSET DRIVE, MECHANICSBURG, P A I7055"~""'" '-"'\'."",,'" WRIT OF EXECUTION and/or A TT ACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due IRWIN UNION BANK AND TRUST COMPANY, Plaintiff (s) From ROBERT A. POORMAN, A/KJA ROBERT L. POORMAN, DEBORA A. POORMAN (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL NO 03-2426 Civil CIVIL ACTION - LAW 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 attachment has been issued; (b) the garnishee(s) is enjoined from payiog aoy 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 defendaot(s) oat 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 garnishee and is enjoined as above stated. Amount Due $94,280.27 L.L. Interest FROM 7/17/03 TO 6/8/05 (PER DIEM - $15.50 - $10,726.00 AND COSTS Atty's Conun % Due Prothy $1.00 Atty Paid $979.99 Plaintiff Paid Date: MARCH 3, 2005 Other Costs CURTIS R. LONG (Seal) ProthoZ ~ I'l... D P 7?zeJ?/?/L 0 Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 62205 Real Estate Sale #44 On March 10, 2005 the Sherifflevied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA Known and numbered as 3815 Dorset Drive, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 10,2005 ByJ8chjJ~ Real Estate Deputy -.. = = <...M :') ::.::C) . ~": -'11 ,~j -..., :-') r'1 C) 3: :to- = I co - :~j ;__~PI ":':5;2 ~Fi1 -<~ ;:0 -'- ..., )I;!"Tl D '*' -<=' o ~ c;s;1 c:: ';1 ~o ~ -'':"'' , THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Connnonwealth ofPennsylvaoia, Connty ofOauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing nnder the laws of the Connnonwealth ofPennsylvaoia, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, Connty ofOauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Snnday Patriot-News newspapers of general circulation, printed aod published at 812 to 818 Market Street, in the City, Connty and State aforesaid; that The Patriot-News and The Snnday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Snnday/ Metro editions which appeared on the 26th day(s) of April and the 3rd aod lOth day(s) of May 2005. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all ofthe 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 Compaoy and subsequently duly recorded in the office for the Recording ofOeeds in and for said Connty ofOauphin in Miscellaoeous Book "M", Volume 14, Page 317. COPY SALE #44 Sworn to and subscn before mylljis 25th day of /}// f//G NOT RY PUBLIC My commission expires Inne 6, 2006 PUBLICATION CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 , Statement of Advertising Costs , To THE PATRIOT-NEWS CO. For publishing the notice or publication attached hereto on the above stated dates 346.69 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News aod The Snnday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice aod publication costs and certifies that the same have been duly paid. By.................................................................... REALb.~~.44 WI'II.... CIvIl . . Irwin Un/clo\ 1IlInk_ 1\'U8t CooI~ v. RobertA............. lIIIrIII'Robert L'""",,-,_ .....A.~I"-I Atty: 0IInW.......... DESeRIPllON . All. TIIAT CEIII"AIN "'" << pIlI:ci of IaDd 811d~,......,lyiq8lldbeillgintbe T......mp of I/ampcIal in tbe Coaoty of ~8IId~"ofl'tmlsylvaoia, .... pIJlicuIady. descdbod" tbIIoo&: ..1\ElNG !.Il147, JiiDPIooOd, Pbase n," =-led in CumIli:daDd~ I'Iao Boot 55, l'a&o!l.l,....J.""icuIodYbouoded8llddoocribed asfoUows. to WIt: . BIlOINNING it a poiDl in tbe _ side of IlixaetDrivosaidpoiDla/loboinga_of SiJ. _ /l"moty Foot 8IId ODe One- _...(6lJ4j)l~_ofdle_on of \be _ side of Cbippcobaln \load. and' tbe Soulh aide ofllixaet~,~ by die line of !.Il No. 148 _ !my deglees dlirty two _ Iweoly """"'" _ (S 40 <leg. 32' 11I"W)._ofOlle_~and Seveoty SiJ. ~ !IotllI9.76') to a !"'in' in AT&T riPl-of"""'J;!l1ine li!.llNo, 166. IIampdoD Squat _.~\'loB B60t 51.,~2; tbea1:e.by..... 8IId !.Il,No.167 !lIir.fl depoea ___~two~ Weat 50 <leg.!s' 42" W) a _ ofNluoly Five aDd FitlySixOlle_tbet~56')IO'point; tbea1:e by !.Il No. 167 lid sQly line depoea __!my Ii.. """""'W'" (N 63 <leg. 13' 45" W) a _ of Foor aDd /l"moty Eipl~~tbet(4JllnlO'pl!QIl.1i!t! of!.ll No. 146;,llIm>::e by..... MIdI ftIty depoea dlirty twO"""'''''- _East (N 40 <leg. 32' 11I"1l). _ of ODe - 1Wcoly Two 8IId ~ ~!Iot (12219') to apoiDl...dIe SoiJIhaideofllixaet Dmo, tbea1:e by_ SOaIb!my_.... ....... .....ptY_IlaII(S 49 ~~'40"ll)a_ofOlle_!Iot (IOOlll) totbe placeof1ll!GlllNlNG' CIiNI'AOONG 12jXJ8JO __ !Iot,tuown and IlUIIIbeftd ai 3815 Ilixaet Ddvo, ~.... i.hl,PAJ705S. TII'UlTOSAIDpremiaeaia _inRollcrt ~. lIlIIIlltIKriA.'-,liia"O\fe,by Doed lames R. ~"'" Laura T. _, . de,daIod4ll2il998"",_ 4IDJ199Il1n Boot 175," 1026. TAX .1l1-\f>1~154. PRIiBl _ Dd.., ~: I_'IU PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYL VANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esqnire, 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: J\priI15,22,29,2005 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 29 day of April SEAL LOIS E. SNYDER, Notary Public Carlisle BolO, Cumberland County My Commission EJcpires March 5. 2009 REAL ESTATE SALE NO. 44 WIit No. 2003-2426 Civil Irwin Union Bank and 'frust Company v.. RobertA. Poorman, a/k/a Robert L. Poorman and Debora A. Poorman Atty.: Daniel Schmieg LEGAL DESCRIPTION ALL THAT CERTAIN tract or par- cel of land and premises, situate, ly- ing and being in the Township of Hampden in the County of Cumber- land and Commonwealth ofPennsyl- vania. more particularly described as follows: BEING Lot #47, Kingswood, Phase 11. as recorded in Cumber~ land County Plan Book 55. Page 93. more particularly bounded and de- scr.lbed as [onaws, to wit: BEGINNING at a point in the South side of Dorset Drive said point also being a distance of Six Hun- dred Ninety-Four and One One-Hun- dredths feet [694.01') West of the intersectiuH of the West side :::f Chippenham Road and the South side of Dorset Drive, thence by the line of Lot No, 148 South forty de- grees thirty-two minutes twenty sec- onds West (S 40 32' 20" W) a dis- tance of One Hundred Nineteen and Seventy-Six One-Hundredths feet (119.76') to a point in AT&T light of way, at line ofLat No. 166 Hampden Square Section I. Plan Book 51, Page 2: thence by same and Lot No. 167 North fifty degrees fifteen min- utes forty-two seconds West (N 50 15' 42" \VJ a distance of Ninety-Five and Fifty-Six One Hundredths feet (95.56') to a poJnt; thence by Lot No. 167 North sixty-three degrees thirteen rrtlnutes forty-five seconds West [N 63 13' 45" W) a distance of Four and Ninety-Eight One Hun- dredths feet (4.98') to a point a line of Lot No. 146; thence by same North forty degrees thirty-two min- utes twenty seconds East IN 40 32' 20" El a distance of One Hundred Twenty-Two and Nineteen One-Hun- dredths feet (122.19') to a point on the South side of Dorset Drive; thence by same South forty-nine degrees twenty-seven minutes forty seconds East (S 49 27' 40" EJ a dis- tance of One Hundred feet (100.00) to the place of beginning. CONTAINING 12.008.30 square feet, known and numbered as 3815 Dorset Drive. Mechanicsburg, PA 17055. TITLE TO SAID PREMISES IS VESTED IN Robert A. Poorman and Debora A. Poorman. his wife by Deed from James R Hegeman and Laura T. Hegeman, his wife dated 4/22/1998 and recorded 4/23/ 1998 in Record Book 175. Page 1026. TAX PARCEL #10-16-1056-154. PREMISES BEING: 3815 DOR- SET DRIVE. MECHANICSBURG. PA 17055.