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Home My WebLink About01-04276GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPa A. GOLDBECB:, JR. ATTORNEX I.D. #16132 SUITE 500 -THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PaILADELPHIA,PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. SHERRY R. WANCHO Mortgagor(s) and Real Owner(s) 501 Park Avenue New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE C-1VIL ACTIOMTpTQ14QE 1~3REGL®~URE THIS FIRM I5 A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAIlVED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish m defend against the claims se[ forth in the foltowing pages, you must fake acfion within twenty (20) days after the Complain[ and notice aze served, by entering a written appearance personally m by attorney and fding in writing with the wort yom defenses or objecfiwe m the claims set forth against you. You are warned that if you fail to do so the case may proceed witl~outyou and a judgmentmay be entered againstyouby the Court witbont further notice for any money claimin flee Complaint of for any otim claim or relief requested by [he Plaintiff You may lose money or property or other rights imporhant to you. YOU SHOULD TAKE THIS POPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO F[ND OUT WHERE YOU CAN GET LEGAL IBiLP. LEGAL SERVICES INC B Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avwue Carlisle, PA 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESEMADAS, ES ABSOLUTAMENTE NECESSARIO QUfi USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVBJO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRTTA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OB7ECCION CONTRA LAS QUEIAS IN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PAATICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIETCAAIQ DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION. ES POSSIBLE QUE USTED PUEDA PERDER DEVERO, PROPIEDAD U OTROS DERECHOS E1~ORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. LEGAL SERVICES INC B Irvine Raw Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 ~~ ~~ ~~~~ k1 ~' ~'~° °; ~~ ~l'~. E I§~?fl ,. ,fir l~~s' COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is COUNTRYWIDE HOME LOANS INC., 7105 Corporate Drive, PTX B-35 Plano, TX 75024-3632. 2. The name(s) and address(es) of the Defendant(s) is/are SHERRY R. WANCHO, 501 Park Avenue, New Cumberland, PA 17070, who is/are the mortgagor(s) and real owner(s) of the mortgaged premises hereinafter described.. On July 28, 1999 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to COUNTRYWIDE HOME LOANS INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1560 Page 332. The mortgage has not been assigned unless said assignment to the Plaintiff is hereafter mentioned. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payment of principal and interest upon said mortgage due March Ol, 2001, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest from 02/01/2001 through 07/31/2001 at 8.0000% Per Diem interest rate at $18.76 Attorney's Fee at 5.0% of Principal Balance Late Charges from 03/01/2001 to 07/31/2001 Monthly late charge amount at $35.20 Costs of suit and Title Search Escrow Monthly Escrow amount $243.54 $85,628.94 $3,395.56 $4,281.45 $176.00 $560.00 $94,041.95 $0.00 $94,041.95 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 Sheriff's Sale. If the Mortgage is reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually performed. 8. The within mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure in the sum of $94,041.95, together with interest at the rate of $18.76, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the for~e]chosure and sale of the~m~oJrtgyag~ed premises. G DBE McCAFFERT & McKEEVER 70SEPH A. GOLDBECK, 7R., ESQLiIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, Michael Vestal, as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therehr-are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworr! falsification to authorities. Date: ~~ . //~f^"~ Michae Vestal Countrywide Home Loans ~s r ALL THAT CERTAIN TRACTOR PARCEL OF LAND AND PREMISES, SITUATE, LYING AND BEING . IN THE BOROUGH OF NEW CUMBERLAND IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY DESCRHIED AS FOLLOWS: - BEGINNING AT A POINT ON THE NORTH SIDE OF PARK AVENUE (60) FEET WIDE), SAD) POINT BEING THE DIVIDING LINE BETWEEN LOT NOS. 6 AND 7, BLOCK °`C", IN THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE NORTHWESTWARDLY ALONG SAID DIVIDING LINE, A DISTANCE OF ONE HUNDRED TEN (110) FEET TO LOT N0.39 ON SAID PLAN; THENCE NORTHEASTWARDLYRLONG SAID LOT. 39, A DISTANCE OF FORTY-NINE AND SLYTY-SEVEN HUNDREDTHS (409.6'7) FEET TO LOT N0.3 ON SAID PLAN; THENCE EASTWARDLY ALONG LOT NOS. 3 AND 4. A DISTANCE OF EIGHTY AND FOUR-TENTHS (80.4) FEET TO LOT NO. S; THENCE SOUTHEASTWARDLY ALONG SAID LOT NO: 5, A DISTANCE OF FORTY-ONE AND FIFTY-EIGHT HUNDREDTHS (41.58) FEET TO A POINT ON THE NORTH SIDE OF PARK AVENUE; THENCE ALONG TAE NORTH SIDE OF PARK AVENUE, SOUTHWESTWARDLY ALONG A CURVE, HAVING A RADHJS OF TWO HUNDRED FORTY-FIVE (245) FEET, AN ARC DISTANCE OF TWENTYSEVEN AND EIGHT-THREE IiiJNDREDTHS (27.83) FEET TO A POINT; THENCE STILL SQUTHWESTWARDLY ALONG PARK AVENUE, A DISTANCE OF SEVENTY AND NINETY-NINE HUNDREDTHS (70.99) FEET TO LOT N0.7, THE PLACE QF BEGINNING. DEED FROM ANNETTE BASALYGA, SINGLE PERSON. AS SET FORTH IN DEED 181 PAGE 667 DATED 6/24/1998 AND RECORDED 7/17/1998, CUMBERLAND COUNTRY RECORDS, COMMONWEALTH OF PENNSYLVANIA. v, S SHERIFF'S RETURN - REGULAR CASE N0: 2001-04276 P COMMONWEALTH OF PENNSYLVANIA: COUNTY Or CUMBERLAND COUNTRYWIDE HOME LOANS INC VS WANCHO SHERRY R DEP ROBERT FINK SR Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon WANCHO SHERRY R the DEFENDANT at 1455:00 HOURS, on the 19th day of July 2001 at 501 PARK AVENUE NEW CUMBERLAND, PA 170,70 SHERRY WANCHO by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 11.05 Affidavit .00 Surcharge 10.00 .00 39.05 Sworn and Subscribed to before me this ,ty ~ day of ~ ,2ti 0 ~ A . D . ~t~. rothonotary So Answers: R. Thomas Kline 07/20/2001 GOLDBECK „ CCAFFERTY & MCKEEVE _ By. ~ ~~ Deputy Sheriff GOLDBECK McCAFFERTY & McKEEVER By: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 115) 627-7322 Countrywide Home Loans, Inc. 7105 Corporate Drive, PTX B-35 Plano, TX 75024-3632 Vs. Sherry R. Wancho 501 Park Avenue New Cuumberland, PA 17070 PRAECIPE FOR JUDG~NT FOR FAILURE TO ANSWER A_uD ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against Sherrv R_ Wancho. Defendant for failure to file an Answer to Plaintiff's Complaint within 20 days (or 60 days if defendant is the United States of America) from the date of service of the complain and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $94,041.95 Interest - 8/1/01 - 9/12/01 $ 806.68 Late Charges $ 70.40 Escrow Debit S 487.08 TOTAL $95,406.11 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. DAMAGES (ACRE HEREBY ASSESSED AS DATE : J ~' rrl- I V ~GY~ I ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO 01-4276-Civil Jo ph oldbeck, Jr. A orne or Plaintiff INDI ED. ''~J G+sL ~ '` . PRO PROTHY I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is 7105 Corporate Drive, PTX B-35, Plano, TX 75024-3632 and that the name and last known address of the Defendant is: Sherry R. Wancho, 501 Park Avenue, New Cumberland, PA 17070 Jo h A. oldbeck, Jr. At rney or Plaintiff .. THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: August 9, 2001 To: SHERRY R. WANCHO 501 Park Avenue New Cumberland, PA 17070 COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX 8-35 Plano. TX 75024-3632 vs. SHERRY R. WANCHO (Mortgagor(s) and Recard Owner(s)) 501 Park Avenue New Cumberland, PA 17070 Plaintiff Defendant(s) T0: SHERRY R. WANCHO 501 Park Avenue New Cumberland, PA 17070 IN THE COURT OF COMMON PLEA5 of Cumberland County CIVIL ACTION -LAW Action of MORTGAGE FORECLOSURE Term No. 01-4276 Civil Term IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COCN'rY BARASSOCIATTON 2 Liberty Avame Carlisle, PA 19013 LEGAL SERVICPS A'C 8 ovine ROw Carlisle, PA 19013 919443-9400 I C '4cCAFEER Z EVER B seph A. Goldbeck, Jr., Esq. Attorney far Plaintiff Suite 500 -The Bourse Btdg. 111 S. Independence Mall Fast Philadelphia,PA 19106 215-627-1322 .~ ~~ ~J ~ r ~'a `-~' 'F; v r,' rn . ~ '~ -a Y.., ., -..- °~.' i GOLDBECK, MCCAFFERTY & MCKEEVER By: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500-The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 Countrywide Home Loans, Inc. Vs. Sherry R. Wancho ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION No. O1-4276-Civil CUMBERLAND COUNTY JOSEPH A. GOLDBECK, JR., ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant is 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 Sherry R. Wancho, is over 18 years of age, and resides at 501 Park Avenue, New Cumberland, PA 17070. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. JO PH A LDBECK, JR. A orne or Plaintiff September 12, 2001 e' `~= -~: G, Win" ~'_ __ ;r'. c~, , _ ~, .- C_ { '' G r1 = "_ J ..o ~fi?rn+.m. -..cam _a..;_<:., . ne;xu'x*~: . '- Bas~3m`~r'n=ASirFC~m~3sfiwps (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Countrywide Home Loans, Inc. Plaintiff Vs. N0. 01-4276-Civil Sherry R. Wancho Defendant Notice is given that a Judgment in the above captioned matter has been entered against you on September 1~, 2001. If you have any questions concerning this matter please contact: Jose A. dbeck, Jr. Atto ey f Plaintiff **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** =.1 . - ~~~. PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 Countrywide Home Loans, Inc. Plaintiff Vs. Sherry R. Wancho Defendant TO THE OFFICE OF THE PROTHONOTARY: COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO: 01-4276-Civil PRASCIPE FOR WRIT OF SXECUTION (MORTGAGE FORECLOSURS) Issue writ of execution in the above matter: Amount Due $95,406.11 Interest from 9/12/01 to sale date S and Costs at $15.68 per diem Total $ Jo ,ph A. oldbeck, Jr. S 'te 50 -The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 Attorney for Plaintiff Note: Please attach description of property. ),~. ~'„ ` .,~ .~, U ~o n N O z° W ~ ~ ~ Vl ~~ii U ~ H a a ai ~ a u ~ a w ~ U ~ ~p ~ U ~7 ^ E O `~ U H x U m y ~ N V N ~w a o~ w v W a%i H '~. U ... b N .~ w O O r-I a 4-I ~ ~ fa ~ ~ ~~' x m ~, `~`' a v ,~ o m ~z N ,~ v ~ ~ "d N m N A ro e W N N ~+ v ~, N 3 y _ .. .. Rma . wx:,,,R „ rr.,:.., =..y.a.i ~}3fu'.wy~Jf:~:. .. R .. GOLDBECK McCAFFERTY & McKEEVER By: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 -The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215 627-1322 Countrywide Home Loans, Inc. 7105 Corporate Drive, PTX B-35 Plano, TX 75024-3632 Vs. Sherry R. Wancho 501 Park Avenue New Cumberland, PA 17070 ATTORNEY FOR PLAINTIFF :CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO O1-4276-Civil ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the`Borough of New Cumberland in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the north side of Park Avenue (60) feet wide, said point being the dividing line between lots nos. 6 and 7, block "C", in the hereinafter mentioned plan of lots; thence Northwestwardly along said dividing line, a distance of one hundred ten (110) feet to lot no. 39 on said plan; thence northeastwardly along said lot 39, a distance of forty-nine and sixty-seven hundredths (49.67) feet to lot no. 3 on said plan; thence eastwardly along lot nos. 3 and 4, a distance of eighty and four tenths (80.4) feet to lot no. 5; thence southeastwardly along said lot No. 5, a distance of forty-one and fifty-eight hundredths (41.58) feet to a point on the north side of Park Avenue; thence along the north side of Park Avenue, southwestwardly along a curve, having a radius of two hundred forty-five (245) feet, an arc distance of twenty-seven and eighty-three hundredths (27.83) feet to a point; thence still southwestwardly along Park Avenue, a distance of seventy and ninety-nine hundredths (70.99) feet to lot no. 7, the place of BEGINNING. Tax parcel#(143) 26-24-24-0811 Being known as 501 Park Avenue, New Cumberland, PA 17070 ., , .. ~ ~ i Jn ~ ~ ~~, c ~~~~~ ~c c~ ~ ~ a t ._. ~;, 'V ~ ~~ u' - ., A vE ~ r.z ., o~ -s .:. ` Countrywide Home Loans, Inc. Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Vs. Sherry R. Wancho Defendant NO. 01-4276-Civil (!~+++n t+^~wiAa xome Loans. TnC., Plaintiff in the above action, by its attorney, Joseph Goldbeck, Jr., Esquire, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ~ni park Avenue New Cumberland PA 17070. 1. Name and address of owner(s) or reputed owner (s): Name Address (if address cannot be reasonably ascertained, please so indicate) .her R. Wancho 501 Park Avenue New Cumberland. PA 17070 2. Name and address of defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please so indicate) 4. Name and address of the last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please so indicate) 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please so indicate) 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate) Pa Dept. of Public Welfare Flealth and Welfare Bldg, Room 432 Bureau of Child Sunnort Enforcement P.O. Box 2675 Harrisburg PA 17105 7. Name and address of every other person of whom the plaintiff has knowledge that has any interest in the property that may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. #4904 relating to unsworn falsification to authorities. September 12, 2001 Jo ph A. ldbeck, Jr. A rney r Plaintiff r; ~' '= r ._ ~ "` C/) - ETIi.'. 'T.7 ?~ l_- °~° J C~ i :~ t'1 G - -t ^C '~ ..~ yC) --G i~ emus u. w..c~s.+.re _ 'cA~ .~N~usrcr~~ 3n, smm i Ft€ena~LYk;hF'v9fl°~d1~Ya v4+c~uavtlP,EiN&"~451t.. .. F GOLDBECK, MCCAFFERTY & MCKEEVER By: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500-The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 (215) 627-1322 Countrywide Home Loans, Inc. Civil Vs. Sherry R. wancho ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL DIVISION NO. 01-4276- JOSEPH A. GOLDBECK, JR., ESQUIRE, hereby states that he is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because it is: (X) an FHA Mortgage ( ) non-owner occupied ( ) vacant ( ) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. Jose A, dbeck, Jr. Att ey f Plaintiff ll (,9 ~ ~. ~. ~:~ a ~° L~ ~ ~~ ~ _ ~~.' ~t ~T l I~~ G~u:.~. ~ -- ~N' ? ' __ ~ l 'p ~~ a } _: (_~ ~" " ' ~ =i ~ ~. ~ ^..3 <.; ? _ g? .. .: PRR~%~f?+x:~ex*s-L'YNn .•. YJey'R~}wwu'4f ^.,%~iIGIN4' S'A - , ~. '"~ ~GOLDBECK McCAFFERTY & McKEEVER By: Joseph A. Go7.dbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 ( .~ ) 6 -7-~ 3 . . Countrywide Home Loans, Inc. Plaintiff Vs. ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Sherry R. Wancho N0.01-4276-Civil Defendant r\TnTTCE OF SHERTFF ~ S SA7,E OF REP T, ES'T'A'T'E TO: Sherry R, p~ancho 501 Park Avenue New Cumberland, PA 17070 THIS FIRM TS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. Your house (real estate) at 501 Park Avenue New Cumberland. PA 17070. is scheduled to be sold at the Sheriff's Sale on December 5, 2001 at 10:00 a.m., in Cumberland County, Cumberland County Courthouse, Commissioners Hearing Room, 2"d Floor, Carlisle, PA 17013 to enforce the court judgment of $95 406.11 obtained by Countrywide Home Loans. Inc. (the mortgagee) against you. NO OF OUiNi+'R' G RT HT vO av BT.' Lg m0 REV N'^ TH1' HFRTFF' C SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the Back payments, late charges, costs and reasonable attorneys Fees due. To find out how much you must pay, you may call: (2151 627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. ., j You may need an attorney 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.) vOU NLnv 4mTLL 88 ABLx' TO SAVE vOUR DROPS;RTv p~~ vOU H_AVF' O'~'uER RT(]F;TS BVEhT TF THE SHERIFF'S SALE DOES mA_uE 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 .~ ~ 1 6 7-i 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff's office at (7i 7) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At this time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff within 30 days of the Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the Schedule of Distribution. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCB. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOV CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17103 (800) 990-9108 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17103 (717) 243-9400 C7 ~:~ - ``; -a I3 cn -. ~:it~- :~. :~ ~ - 4_ C^.:= -~ :,, ~- c~ L ~': ~ ~' -r L r3 ..,} -<. GOLDBECK McCiAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff Alliance Funding, a division of Superior Bank, FSB One Ramland Road Orangeburg, NY 10962 Plaintiff vs. SHERRY R. WANCHO 501 Park Avenue New Cumberland, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE PA 17070 Defendant Term No. O1-4276-Civil Term CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2(c)(2) Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ( ) Personal Service by the Sheriff's Office/competent adult (copy of return attached). (~ Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). ( ) Certified mail by Sheriff's Office. ( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriff's Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriff's Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriff's Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriff's Office (copy of return attached). ( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respec BY: Jos A. Goldbe~k, Jr. Attorne for Plaintiff 2. Artlole Number ' ~• - A. rierslve ' ~j.: j' i i;' X - D. Is delM j 3. Service Type CERTIFIED MAIL ~- ^ Yes ? 4 Restdcted DeliveM (Extra Feel 7. Article Adtlressed to: WANCHQ SHERRY R. ' ~ -° SHERRY R. WANCifiO' 501 Park Avenue New Cumberland, PA 17070 Agen[ ptldreasee t~ 'RE: SENDER: ~~, 15 1 U i GOLgSECKMCCAFFERTY &MCKEEVER h I J t w.ti rxo P,J ~6riR x'11, iltine?2d00 Domestic Return Receipt 7106 4575 1294 4604 0742 TO: WANCH~, SHERRY R. SHERRY R. WANCHO 501 Pazk Avenue New Cumberland, PA 17070 SENDER: GOLDBECK MCCAFFERTY&MCKEEVER September 12, 2001 REFER NCE: wAlvcxo,sxERRYR.(cwD-tsar ~L ~ I -Cumberland RETURN Postage RECEIPT Cert'rfied Fee SERVICE Re[um Receipt Fee Restricted Delivery _ ~ Total Postage & Fees ' , US Postal SONICe ~ y. POSTgA131~(Oii~DATE~~ . ~ , f ~, . . Receipt for ~~ / ~_`'" ' ,~ Certified Mail ~ ~~ ._we ~'~` No Insurance Coverage Provided „+"' Do Not Use for International Mail V N 0 3 W -J N a 0 YYYppp~777 o ~ 3 s 0 a O 1 x O W .Q 0 w a a f 4 w o (P A W 1 N O (9 ~ J O W. A W N r m ~ n d maa o~ I ~ 'm NP m b n 60 . 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OO Z x °O ~ ~` h ~ ~ ~ ° e : y ~ ~ N F ~ oo^~L`~u ~ Ie~ 3 e"Y~:3 N 1~ T A n '$aCP 33 y yy .a ~ Z mA1 m m «• n f+ . .. ~„TTT a i ~T m~ n ~ .i V~ m A m ° ~4 aPe g '° - OO..a W` m a a3 ~~ v a..a mn s°3c3o am X3 m lD a + N ~ g0 ° a °'aC'noa e $ ~ o mx 3 N mw a o sS ~3a ~ ~ ~g'¢.'°.a m v A~ a a i GMO n . n Dl N aa mm> 3 7 m ~ ~ :$x ~~n°2 Tp R O 0 ¢~ ~ v o3 ° ~ el3 °aom n o' ~ ° ~, , ~~ m° n' ~ - 3 j . . dog3w~ -oa~o< m s '~ ~m~wom . z . ~ ° o s m m ; . .,. ~. , ,.. i~ ,m .x ~~ ~n ~~rnrn y~ n~ ~~ a Ily~~l W i m 6 m _ u w C n ~~~s r'~ ,. d .~,. Countrywide Home Loans, Inc. Plaintiff CUbIDERLAND COUNTY COURT OF CONMON PLEAS CIVIL DIVISION Vs. Sherry R. Wancho Defendant NO. 01-4276-Civil Countrvw;de Home T•oans. Inc., Plaintiff in the above action, by its attorney, Joseph Goldbeck, Jr., Esquire, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at Sn'I nark Avenue New Cu+~1~e+-~ and PA 17070. 1. Name and address of owner(s) or reputed owner (s): Name Address (if address cannot be reasonably ascertained, please so indicate) Sherry R. Wancho 501 Park Avenue New Cumberland PA 17070 2. Name and address of defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please so indicate) 4. Name and address of the last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please so indicate) 5. Name and address of every other person who has any record ' lien on the property: Name Address (if address cannot be reasonably ascertained, please so indicate) 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate) Pa Dept. of Public Welfare Health and Welfare Bldg Room 432 Bureau of Child Support 8nforcement P.O. Box 2675 Harrisburg, PA 17105 7. Name and address of every other person of whom the plaintiff has knowledge that has any interest in the property that may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. #4904 relating to unsworn falsification to authorities. September 12, 2001 Jo ph A. ldbeck, Jr. A rney r Plaintiff ~ n ~ ~_ -_ ., ~n ~ ,~ ~~ _~ j~ ~ ~~ GG 'D -s- it 'ri D ~ ? rr ,, Countrywide Home Loans, Inc. VS Sherry R. Wancho In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-4276 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Joseph A. Goldbeck. Sheriff's Costs: Docketing Surcharge Posting Handbills Law Library Prothonotary Share of Bills Mileage Levy Advertising Certified Mail Poundage Postpone Sale Law Journal Patriot News 30.00 20.00 15.00 .50 1.00 25.66 22.10 15.00 15.00 1.47 12.83 260.75 32 4.93 $654.24 paid by attorney Sworn and subscribed to before me ~ swe!~~ r~; ~ This ~a `-` day of ~i-Qee~..~i~-.-i 'd"6 ~-~ R. Thomas Kline, Sheriff 2001, A.D. r BY~i~ Prothonotary R al E ate Deputy (~ c~lz.. 3^1419 %f4GF'1 M Countrywide Home Loans, Ine. Plaintiff Vs. Sherry R. Wancho Defendant ~ ~ CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-4276-Civil c'~++++*x-=,.w~de Home T•oans Inc., Plaintiff in the above action, by its attorney, Joseph Goldbeck, Jr., Esquire, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 50~ Pa+-k Avenue New Cumberland, PA 17070. 1. Name and address of owner(s) or reputed owner (s): Name Address (if address cannot be reasonably: ascertained, please so indicate) Sherrv R. Wancho 501 Park Avenue = New Cumberland PA 17070 2. Name and address of defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) 3. Name and address"of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please so indicate) 4. Name and address of the last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please so indicate) C 5.~ N431@ t Name and address of every other person who has any record lien on the property: Name 6. Name and address interest in the by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate) of every other person who has any record property and whose interest may be affected Address (if address cannot be reasonably ascertained, please so indicate) p_a Dep of P ~+ W Mare Health and Welfare Bldg Room 432 Bureau of Child SuDDOrt Enforcement P.O. Box 2675 Harrisburg, PA 17105 7. Name and address of every other person of whom the plaintiff has knowledge that has any interest in the property that may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ##4904 relating to unsworn falsification to authorities. September 12, 2001 Jo ph A. ldbeck, Jr. A rney r Plaintiff ` '~ GOLDBECK MCCAFFERTY & McKEEVER By: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 1~)~Z-_1.327 Countrywide Home Loans, Inc. Plaintiff Vs. ATTORNEY FOR PLAINTIFF CUMBERLAND BOUNTY COURT OF COMMON PLEAS CIVIL DIVISION Sherry R. Wancho NO.O1-4276-Civil Defendant Ti0 T O H T F' T O RFAT 9 AT T0: Sherry R. Wancho 501 Park Avenue New Cumberland, PA 17070 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. Your house (real estate) at 501 Park Avenue, New Cumberland. PA 17070. is scheduled to be sold at the Sheriff's Sale on December 5. 2001 at 10:00 a.m., in Cumberland County, Cumberland County Courthouse, Commissioners Hearing Room, 2"a Floor, Carlisle, PA 17013 to enforce the court judgment of $95.406.11 obtained by Countnrwide Home Loans. inc. (the mortgagee) against you. NOTICR OF OWNBR'S RIGHTS ~'OU Hiny B8 L8 m0 PRF~n'*"~' mur4 SHFRTFF' S SALF To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the Back payments, late charges, costs and reasonable attorneys Fees due. To find out how much you must pay, you may call: (2151 627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. -~ . a. ' .• 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.) Yf]Tr MAV QTTL.r. RR ART.F. TO SAVE YOUR PROPERTY AND YOU RAVE OTHER $rrum8 EVEN rg mHE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (.~5) 6-7-r 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff's office at (717) 240-6340. 9. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At this time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff within 30 days pf the Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the Schedule of Distribution. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TEL$PHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17103 (800) 990-9108 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17103 (717) 243-9400 ~_ . . GOLDBECK McCAFFERTY & McKEEVER By: Joseph A. Goldbeck, Jr. Attorney LD. #16132 Suite 500 -The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 (215)627-1322 Countrywide Home Loans, Inc. 7105 Corporate Drive, PTX B-35 Plano, TX 75024-3632 Vs. Sherry R Wancho 501 Park Avenue New Cumberland, PA 17070 ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO 01-4276-Civil ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Borough of New Cumberland in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the north side of Park Avenue (60) feet wide, said point being the dividing line between lots nos. 6 and 7, block "C", in the hereinafter mentioned plan of lots; thence Northwestwardly along said dividing line, a distance of one hundred ten (110) feet to lot no. 39 on said plan; thence northeastwardly along said lot 39, a distance of forty-nine and sixty-seven hundredths (49.67) feet to lot no. 3 on said plan; thence eastwardly along lot nos. 3 and 4, a distance of eighty and four tenths (80.4) feet to lot no. 5; thence southeastwardly along said lot No. 5, a distance of forty-one and fifty-eight hundredths (41.58) feet to a point on the north side of Park Avenue; thence along the north side of Park Avenue, southwestwardly along a curve, having a radius of two hundred forty-five (245) feet, an arc distance of twenty-seven and eighty-three hundredths (27.83) feet to a point; thence still southwestwardly along Park Avenue, a distance of seventy and ninety-nine hundredths (70.99) feet to lot no. 7, the place of BEGINNING. Tax parcel#(143) 26-24-24-0811 Being known as 501 Park Avenue, New Cumberland, PA 17070 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. COUNTY OF CUMBERLAND) TO THE SHERIFF OF Cumberland COUNTY: 01-4276 CIVIL 1~ ~~ CIVIL ACTION -LAW To satisfy the debt, interest and costs due Countrywide Hcrtte Loans, INC. from Sherry R. Wancho, 501 Park Avenue, New Cumberland, PA 17070 (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as folbws: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) Itpropertyofthedefendant(s)notlevieduponansubjecttoattachmentisfoundinthepogsessionofanypneother than a named garnishee, you are directed to notfy him/herthat he/she has been added as a garnishee and is enjojn~d as above stated. Amount Due 595,406.11 L.L. $.50 Interest fran 9/12/01 to ,sale date at Due Prothy Atty's Comm Atty Paid _ Plaintiti Paid Dale: $111.05 Septettber 18, 2001 REQUESTING PARTY: Name Joseph A. Goldbeck, Jr., Esq. Address: Suite 500-The Bourse Bldg. S. In epe ence as Fl~~ad°~ =a, PA-1Q 10fi Attorney tor: P7-aintiff Telephone: 215-627-1322 Supreme Court ID No. 16132 $1.00 Other Costs Curtis R. Long Prothonotary, Civil Division Deputy REAL ESTATE SALE No. 52 On September 19, 2001, the sheriff levied upon the defendant's interest in the real property situated in Borough of New Cumberland, Cumberland County, PA, known and numbered as 501 Park Ave., New Cumberland, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 19, 2001 By: ~~~ ~~~~ ~ Real Estate Deputy c~ a g .,. ~,.: _.-. -. e,:.,, :w,p3gy#iryP+'"iP1W'.f.,~i~Aifk~~3uRTF~NbT3~A., k:::. _~en~KrcmA_ N~tA~ P~wl#MP~Rfrt+~4~=j%ay PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (iJnder Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 12, 19, 26, 2001 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. /°_'~- Rog M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 26 day of OCTOBER. 2001_ NOTARIAL-SEAL LOTS E. SNYDER, Notary PUNIC Corbels ®oro, Cumberland Coon My Cammissbn Expires 5, 2 ,.m.~.. _ REAL ESTATE BALE NO. 62 Writ No. 2001-4276 Civll Countrywide Home Loans, Inc. vs. Sherry R. Wancho Attorney Joseph Goldbeck ALL THAT CERTAIN tract or par_ cel of land and premises, situate, h'irig and being in the Borough of New Cumberland in the County of Cumberland and Commonwealth of Pennsylvania, more particulazly de- scribed as follows: BEGINNING at a point on the north side of park Avenue (60) feet wide. said point being the dividing line between lots nos. 6 and 7, block "C," in the hereinafter men- tioned p]an of lots; thence North_ westwardly along said dividing line. a distance of one hundred ten (110) feet to lot no. 39 on said plan; thence northeastwardly along said lot 89, a dista~_ce of forty-pke and sixty-seven hundredths (49.67) feet to lot no. 3 on said plan; thence estwardly along lot nos. 3 and 4, a distance of eighty and four tenths (80.4) feet to lot no. 5; thence south- eastwardly along said lot No. 5, a distance of forty-one and fifty-eight hundredths (41.58) feet to a point on the north side of Park Avenue; thence along the north side of Park Avenue, southwestwardly along a curve, having a radius of two hun- dred forty-five (245) feet, an azc dis- tance of twenty-seven and eighty- three hundredths (27.83) feet to a point; thence still southwestwardly along park Avenue, a distance of seventy and ninety-nine hundredths (70.99) feet to lot no. 7, the place of BEGINNING. TaX parcel #(143) 26-24-240511. Being known as 501 Park Av- enue, New Cumberland, PA 17070. „.. .. a~~e z.spm~ ~uts~.as-+~arary~5°raJi~4>~a, ~~~~4~.%e .. .~. ._. ~_ Po, THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Ad No. 587, Approved May 16,1929 Commonwealth of Pennsylvania; County of Dauphin} ss James L. Clark being duly sworn according to law, deposes and says: That he is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of Tag Patriot-News and T e 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 daily and/or Sunday/ Metro editions which appeared on the 23rd and 30th day(s) of October and the 6th day(s) of November 2001. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin i Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION ........................... ~............;...................................................... COPY SALE #52 1 stn 2001 A.D. Terry L Russell, Notary Public HanlSburg, Daupnln County My Commission Expires June 8, Member,PennsyroanlaassoclntbnorNataAes N TARYPUBLIC My commission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ 233.43 Probating same Notary Fee(s) $ 1.50 Total $ 234.93 Pubiisher'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 ................................................... '"`REA[ ESTATE SALENd.52 -- ---" - _ Writ No.2501-0276 - - - Civil Term -' Countrywide Home Loans, Inc.. vs -- ~ SherryR.Wancho _° __ _ Atly:Joseph Goldbeck efl,t, rk4tiL.t.CKrAUVkaG orparce] of laud and tses„~itpa[e, jytng oast hang in the Horough ew -Cumberland. in the -County of adand and Commonwealth of s-rtiama; more9 padiculazly descdhed as -.. 0 ows - _ -- --- --- ., - _ ~' 1WG a[ a point on the north side of Park ' (601 feet wide, said point heing the ~xv'id,ng me between lots nos. 6 and 7, block "C", - m ehereinartes menfloned plan eE lots; (hence _ ~otthwestwardly along said dividing live, a dlSmnCC of one huvdred ten (110) feet to lot no. '~59- on ,said plan; thence northeastwardly along • - ~7d,o139, a distance of forty-nine and sixty- - seven hundredths(49,67) fret to lot no, 3 on said - , - plan;_thence easnvazdly along lot vas. 3 and 4, a ~ s -distavice.of eighty and fow tenths (80.4) feet m lot :_np: t;'lhence soulheastwardly along said ]ot no. 5, --adistance of Pony-one and fifty-eight hundredths (4(S8) feet to a paint an the nanh side of Pazk Avenue; thence alovg the nonh side of Park Avenge, southwestwazdly along a curve, having a tadins of two huvdred forty-five (Z75) feet an arc Histance oL hven[y-seven and eighty-three hundredths (27.83) feet m a point; thencestill southwestwazdly alovg ]'ark Avenue, a distance of seventy end ninety-nine hundredths (70.99) feet to lotno.7, the place of BEGSNNIN^v. Tax Parcel N(143) 26-Yr24'4081(. BEGVG known as 501 Park Avenue, New Qamberland, PA 17070._ _i__` _ _ _