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HomeMy WebLinkAbout01-04698FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 COUNTRYWIDE HOME LOANS, INC., F/K/A COUNTRYWIDE FUNDING CORPORATION 7105 CORPORATE DRIVE PLANO, TX 72024-3632 Plaintiff v. DOUGLAS C. DISBROW SUSAN E. DISBROW 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 Defendant(s) TERM No. Q I - yC 9~' CUMBERLAND COUNTY CIVII, ACTION -LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIItM 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 REAFFIItMED, 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 aze 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 nonce for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 Loan #:7207317 ATTORNEY FOR PLAIN'T'IFF COURT OF COMMON PLEAS CIVIL DIVISION 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 AFTER 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. ~. Plaintiff is COUNTRYWIDE HOME LOANS, INC., F/K/A COUNTRYWIDE FUNDING CORPORATION 7105 CORPORATE DRIVE PLANO, TX 72024-3632 The name(s) and last known address(es) of the Defendant(s) are: DOUGLAS C. DISBROW SUSAN E. DISBROW 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 10/23/95 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PROVIDENT MORTGAGE CORP. T/A CONSOLIDATED MORT CORP which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1288, Page 862. By Assignment of Mortgage dated 10/23/95 the mortgage was assigned to PROVIDENT BANK OF MARYLAND which Assignment is recorded in Assignment of Mortgage Book No. 507, Page 121. By Assignment of Mortgage dated 10/23/95 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 515, Page 161. 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 12/1/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." ,, . 6. The following amounts are due on the mortgage: Principal Balance $126,316.73 Interest 7,460.10 11/1/00 through 7/1/01 (Per Diem $30.70) Attorney's Fees 4,000.00 Cumulative Late Charges 645.85 10/23/95 to 7/1/01 Cost of Suit and Title Seazch 550.00 Subtotal $138,972.68 Escrow Credit 187.17 Deficit 0.00 Subtotal 187.17 TOTAL $138,785.51 7. The attomey'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. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. The Combined Nofice has been sent to the Defendant(s) by regulaz and certified mail as required by 35 P.S. § 1680.403c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffl s written Nofice to Defendants, a true and correct copy of which is attached hereto as Exhibit "A"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $138,785.51, together with interest from 7/1/01 at the rate of $30.70 per diem to the date of Judgment, and other costs and chazges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. ~F~~-~ /s/ Frank Federman FRANK FEDERMAN, ESQUIl2E Attorney for Plaintiff Send Correspantlence [o: P.O. Box xCOPOBXn rcCOCSTZu Send Payments to: PO. Box aPYPOBXu , rcPVCSTZu a MAILCSnaMAILZPx Certified Mail No. June 02, 2001 Relurn Receipt Requested Regular Mail Douglas C., & Susan E. Disbrow 12 Yankee Ddve Mount Holly Springs, PA. 17065 Countrywide Account # 7207317 Properly Address: 12 Yankee Ddve Mount Holly Springs, PA. 17065 Current Servicer: Countrywide Home Loans, Inc. ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Thts is an official notice that the mortnaoa on your home Is In defauh, and the lentler intands_t_o foreclose Soeciflc Infomlation about the nature of tha default tt orovided In the attached Danes. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAPI may be able to halo to save your home. This Noflce exolalns how the broarem works. To see If HEMAP can help. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Aaencv. This Notice contains important legal Information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help answer them. You may also want to contact an attorney In your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACIGN EN ADJUNTO ES DE SUMA IMPORTANCIA, PUE5 AFECTA SU OERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIbN OBTENGA UNA TRADUCCIGN INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL Nl1MER0 MENCIONADO ARRiBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL COAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT'), YOU MAY BE ELIGIBLE,FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, Please write your loan number on all checks antl correspontlence. 6/26/2000 aMNAMEe aACCTX»-«CHKOGTn rADDRS. aTOTDUE»AS OF aDUEDTE» P.O. BOx «PYPOBX» aPYCSTZ» «BARCDE» '-tWKSCAN3 EXHIBIT A TEMPORARY STAY OF FORECLOSURE -Under the Ad, you are entitled to a temporery stay of foreclosure on your mortgage for thirty-five (35) days firm the date of this Notice. During that time you must grange and attend a "face-to- face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take adion against you for thirty-five (35) tlays after the dale of this necessary to scneoule one to-race meeang. AtlvlSe your lender Immediately of your Inventions. APPLICATION FOR MORTGAGE ASSISTANCE -Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tded and are unable to resolve this problem with the lender, you have the dghl to apply for financial assistance from the Homeowner's Emergency Modgage Assistance Program. To do so, you must fill out, sign and file a completetl Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only censumer credit wunseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be 81ed or postmarked within thirty-five (35) days of your tats-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility critede established by the Ad. The Pennsylvania Housing Finance Agency has sixty (80) days to make a decision after it receives your application. Dudng that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified diredly by the Pennsylvania Housing Finance Agency of Its tlecialon on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) NOTICE OF INTENT TO FORECLOSE YOUR HOME LOAN IS IN DEFAULT FOR THE REASONS SET FORTH IN THIS NOTICE. YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE NATURE OF THE DEFAULT -Countrywide Home Loans, Inc. (hereinafter "Countrywide") services your home loan. Your home loan is in serious default because you have not made your required payments. The total amount now required to reinstate your home loan as of the date of this letter Is as follows: Monthly Payments: $1,288.00 Late Charces: $51.93 Other Charces: Uncolledetl Late Charges: Uncolleded Casts: $7,716.00 $311.58 $282.41 $78.00 TOTAL DUE: $8,387.99 EXHIBIT A . HOW TO CURE THE DEFAULT - Yeu may cure this default within THIRTY-FIVE (35) DAYS of the date of this letter, by paying.to us the above amount of $3,160.20, plus any adtlitlonal monthly payments, late charges, fees and other applicable charges which may fall due. dudng this pedod. Such payment must be in the form of certified check, cashier's check or money order, and made payable to Countrywide at P.O. Box 660894, Dallas, TX 75266-0694. If your check or other payment is retumed to us for insufficient funds or for any other reason, you will not have curetl your default. No extension of time to cure will be grented due to a returned payment. If you do not cure this default within THIRTY-FNE (35) DAYS, we will accelerete the payments due on your home loan. This means whatever is owing on the odginal amount borowed will be considered due immediately and you may lose the chance to pay off your home loan in monthly installments. If the full payment of the amount in default is not made within THIRTY-FIVE (35) DAYS, we also intend to immediately start a lawsuit to foreclose on your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - If the mortgage is foreclosed, the mortgaged property will be sold by the Shedff to pay off the mortgage debt. If the tletault is cured before we begin legal proceedings, Countrywide will be enti8ed to tolled the reasonable attorney's fees actually incurred, up to $50.00. However, if legal proceedings are started, Countrywide will be entitled to tolled the reasonable attomey's fees even if they are over $50.00. Any attomey's fees will be added to the secured debt, which may also inclutle our reasonable costs. If you cure the default within the THIRTY-FIVE (35) DAY pedod, you will not be required to pay attomey's fees. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE NON- EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE. OTHER LENDER REMEDIES -The lender may also sue you personally for the unpaid pdncipal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO FORECLOSURE SALE - If you have not cured the default within the THIRTY-FIVE (35) DAY pedod and foreclosure proceetlings have begun, you still have the right to cure the default and prevent the sale at any t(me up to one hour before the foreclosure sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attomey's fees and costs connected with the foreclosure sale and any Mher costs connected with the foreclosure sale as specified In wrttlng by the lender and by performing any other requirements under the mortgage. Curing your default In fhe manner set forth In this notice will restore your mortgage to the same position as If you had never defaulted. EARLIEST POSSIBLE FORECLOSURE SALE DATE - It is esfimated that the earliest date that a foreclosure sale could be held would be approximately six (6) rtronths from the date of this letter. A notice of the date of the foreclosure sale will be sent to you before the sale. You may Tend out at any time exactly what the requiretl payment will be by calling us at the following number: 80069-5231. This payment must be in the forth of a cashier's check, certified check or money order and made payable to us al the address stated above. If the default is cured, the mortgage will be restored to the same position as if no default had occurred. However, the default may not be cured more than three (3) times in any calendar year. HOW TO CONTACT THE LENDER: Name of Lender: Countrywide Home Loans, Inc. Address: P. O. Box 10221 Van Nuys, CA 91410-0221 Phone Number: 800.589.5231 Fax Number: 1-605-577J432 Contact Person: Christen Roeha, MS SV-34 Altentlon: Loan Counselor EFFECT OF FORECLOSURE SALE -You should realize that a foreclosure sale will end your ownership of the mortgaged property and your right fo remain in it. If you continue to live in the property after the Sheriff s sale, a lawsuit to remove you and your furnishings and other belongings could be started by Countryvdde at any time. ASSUMPTION OF MORTGAGE -Contact Countrywide Home Loans for information on the possible assumability of your loan. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMEB IN ANY CALENDAR YEAR.) AYMENT INSTRUCTIONS Please Make your check payable to CounhyrvMe Home Leans Dodt aflech your check Nthe paymenlceupon WMe year ben number on yourdieck or money order DonY include conasWmlence Wdte in airy addNOnalamounb you are including. (If Don'l sentl cash total is more Nan $50W, Abase send ceNfied check.) ddltlonal anpunb. N yai don't sWdfy the Wryose d additloiml amourde Iimluded, we will eDPN Nem Nsl b any aubbiding ymenb, escrow tlefmiendes. Isle cheedes aiMlm fees due. We w01 Nan appty any remelni~g amounts as a pdndpal reduction. II u submh an addaonal pdndpel payment wOh your home ban payment, Coumrywide will Ant aDDty Your lame loan payment, Nen a add6onel pendpal payment. Your ban mudbe anembeforewe ran appty arty PdndPal reduction. ~XHiBIT A TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BV THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Pursuant to your home loan documents, and because the home loan Is in default, Countrywide may, at its option, enter upon and conduct an inspection of the property. The purpose of this inspection is to observe the physical condition of the property, to verify that the property is occupied andlor to determine the identity of the occupant. The cost of any such Inspection will be added to and become part of the secured debt as provided under the terms of the home loan documents. EXHIBIT A If you are unable to cure your default on or before July 07, 2001, Countrywide wants you to be aware of various options that may be available to you through Countrywide to prevent a foredosure sale of your properly. For example: Reoavment Plan: it is possible that you may be eligible for some form of payment assistance through Countrywide. Our basic plan requires that Countrywide receive, upfront, at least 14 of the amount necessary to bring the account current, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a defined period of lime. Other repayment plans also are available. • Loan Modification: Altematively, it is possible that the regular monthly payments can be lowered through a modification of the loan by reducing the interest rate and then adding the delinquent payments to the current loan balance. This foreclosure ahemative, however, is Iimiletl to certain loan types. • Sale of Your Property: Altematively,rf you are willing to sell your home in order to avoid foreclosure, it is possible that the sale of your home ran be approved through Countrywide even if your home is worth less than what is owed on it. • Deed-in-Lieu: Altematively, if your property is free from other liens or encumbrances, and if the default is due to a serious financial hardship which is beyontl your control, you may be eligible to deed your property directly to the Noleholtler and avoid the foreclosure sale. If you are interested in discussing foreclosure allematives with Countrywide, you must contact us immediately. If you request assistance, Countrywide will determine, in Rs sole discretion, whether such assistance will be extended to you. In the meantime, Countrywide will pursue all of its rights and remedies under the home loan dowments and as permitted by law, unless It agrees otherwise in writing. Please be advised that failure to bdng the home loan current or to enter into a written agreement as outlined above.will result in the exeleretion of the debt. Time is of the essence. Shoultl you have any questions concerning this notice, please contact Countrywide's office immediately at 800-669-5231, eMension 7149. Christen Roche Login Counselor 800-869-5231, Extension 7148 Please be advised that this communication is from a debt collector. EXHIBIT A PE~NSYLVAtYIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY ASSISTANCE PROGR.+uY[ CONSUMER CREDIT COUNSELING AGENCIES (REV.8/00) CLINTON COUNTY Lycoming-Clinton Counties Commision for CCCS of Noaheastem P.4 Community Action (STEP) 1631 South Atheaon St, Suite 100 2li8 Lincoln Sueet P.O. Box ! 328 State College, PA 16801 WiliiamsPOrt, PA 17703 (814) 238-3668 FAX (8l4) 238.3669 (570) 326-0587 FAX (570) 322-2197 CCCS ofNortheastem PA 20l Basin Sneet Williamsport, PA 17703 (570) 323-6627 FAX {570) 323.6626 COLUb(BIA COUNTY 3l W. Market Stree[ 1400 Abington Executive Park POB 1127 Suite l Wilkes-Barre, PA 18702 Clarks Summit PA 1841 I (570) 821-0837 or (800) 922-9537 (570) 5$7.9163 or (800) 922-953 i FAX (570) 821-1785 FAX (570) 587-9134-9135 Commission on Economics Oppommity of Luzeme County 163 Amber Lane Wilkes-Bove, PA 18702 (570) 526-0510 or (800) 822-0359 FAX (570) 829-1665-(Call Before Faxing) (570) 45511994 Hauitown FAX (370) 455-1631--{Call Before Fazing) (570) 836~i090 Tunkhamock CRAWFORD COUNTY Booker T. Washington Center Greater Erie Community Action Commiaee 1720 Holland Center IS West 91° Svee[ Erie, PA 16503 Erie, PA 16501 (814) 453-5744 FAX (8l4) 5749 (814) 459-1581 FAX (813) 356-0161 John E. Kennedy Center, [nc. Shenango Valley Urban League, inc. 2021 East 20'" Sveet 60l Indiana Avenue Erie, PA 16510 Farrell, PA 16121 (814) 398.0400 {412) 981-5310 FAX (8l4) 898-1243 CUMBERLAW COUNTY CCCS of Western Pennsylvania, [nc. Financial Counseling Services of Franklin 2000 Linglestown Road 31 West 3'° Svee[ Hartisburg, PA 17(02 Waynesboro. P.4 17268 (7!7)541-1757 (717)762-3285 Urban League of Mevopolitan Harrisburg YWCA of Cariisle - N. 6'° Sveet 301 "G" Street Harrisburg, PA 17101 Carlisle, PA [7013 : (7! 7) 234-5925 FAX (7!7) 234-9459 (717) 243-3818 FAX (7! 7) 731-9589 Community Action Comm of the Capital Region Adams County Housing Authority 1514 Decry Street 139-143 Carlisle St. Harrisburg, PA 17104 Gettysburg, PA 17325 (717) 232-9757 FAX (717) 234-2227 (717) 334-I S l8 FAX 334-8326 PEVNSYLV,+uYW BULLETM, VOL. 29, NO. ~, JUNE 5, 1999 EXHIBIT A AJ.L that certain tract ofland situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described in accordance with a Plan prepared by Walter N. Heine Associates, Inc., dated December 8, 1989 and recorded in Plan Book 64, Page 90, as follows: 13ECJNNJNC at a point in southern dedicated fight-af--way line of Yankee Drive at comer of Lot No. 41; thence along Yankee Drive by a curve to tits right having a radius of 136.02 Feet and en erc distance of 81.2 fee[ to a point; [hence along Lot No. 43, South 06 degrees 36 minutes 54 seconds East ]36.02 feet to a point; thet[ce along Lot No. 44 on Plan; South 13 degrees 55 minutes 49 seconds East 44.60 feet to a point; thence along Lot No. 45 on Plan of Liberty Woods, South 70 degrees~27 minutes 31 seconds West 45.00 feet to a point; thence aloj~$ Lats 40 and 41 on Plan, North 19 degrees 32 minutes 29 seconds West 171.13 feet to a ptggt, tie i Place of BEGINNING. ~ . CONTAJNJNG 0.2467 acre and designated as Lot No. 42 on Plan of Liberty Woods BEJNC part of the same premises which William H. Nordstrom, Executor of the Estate of Ruth Newburg Moore, e/Wa Ruth E. Moore, by his deed dated October 13, 1992 and recorded in the OtFice of the Recorder of Deeds for Cumberland County in Deed Book "Y", Volume 35, Page 278, granted and conveyed to Liberty Associates, A Partnership, Grantor herein. PREMISES: 12 YANKEE DRIVE VERIFICATION BRANDON SCIUMBATO hereby states that he is VICE PRESIDENT of COUNTRYWIDE HOME LOANS, INC. mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to iincwom falsification to authorities. DATE: ~ ~/ .. n ~~ ~a ~~~ '\ `~` ~ r -~ ~ ~ r= - ., 8 o ~=- r /' ~ r c . ~ ~a"n ~"~ i)~ ' r~ f' '- ~~ ~p ~i'c t I _ ~ e "v (T - C (~ ~a. _. _ .. i ~~%.~. .... _ _ ~#gayt#Ri~uls.~s-ra~a~.cR„ . =. -. y ,~..m x~r.,, ~.~:.p~.. a me rne-i#~wrav~~~~ ,. • , `~ CASE NO: 2001-04698 P !~ SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS DISBROW DOUGLAS C DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon DISBROW DOUGLAS C the DEFENDANT at 0017:14 HOURS, on the 13th day of August 2001 at 12 YANKEE DR MT HOLLY SPRINGS, PA 17065 by handing to DISBROW a true and attested copy of COMPLAINT - MORT FORE together with CE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: bocketing 18.00 Service 4.55 Affidavit .00 Surcharge 10.00 .00 32.55 Sworn and Subscribed to before me this i'7 a= day of Pfrothonotary '-~ So Answers: ~-~~ R. Thomas Kline 08/14/2001 FEDERMAN & PHELAN Deputy/~ f „.- »~, ^, CASE, NO: 2001-04698 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS DISBROW DOUGLAS C ET AL DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon DISBROW SUSAN E the DEFENDANT at 0017:14 HOURS, on the 13th day of August 2001 at 12 YANKEE DR MT HOLLY SPRINGS, PA 17065 SUSAN DISBROW by handing to a true and attested copy of COMPLAINT - MORT NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this /7`~ day of o~D/ A.D. a, ~. i rue.r~.~ ~ rothonotary So Answers: ~~~Q R. Thomas Kline 08/14/2001 FEDERMAN & PHELAN By . ?~~ i~// /t t~1.w~ Deputy Sheriff ~~ FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 COUNTRYWIDE HOME LOANS, INC., F/K/A COUNTRYWIDE FUNDING CORPORATION 7105 CORPORATE DRIVE MOUNT HOLLY SPRINGS, PA 17065 Plaintiff Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-4698 vs. DOUGLAS C. DISBROW SUSAN E. DISBROW 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem, in favor of the Plaintiff and against DOUGLAS C. DISBROW and SUSAN E. DISBROW, Defendant(s), for failure to file an Answer to Plaintiff s 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 hi Complaint $138,785.51 Interest 7/1/01 TO 9/17/01 2,425.30 TOTAL $141,210.81 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached. FRANK FEDERMAN, ESQUII2E Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: ~: PRO PROT **THIS FII2M 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 REAFFntMED, 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. ** _E'C~F"!'A'~' AND oLr'T,AN, L.L.P. Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 COUNTRYWIDE HOME LOANS, INC. F/K/A COUNTRYWIDE FUNDING CORPORATION Plaintiff vs. _ DOUGLAS C. DISBROW SUSAN E. DISBROW Defendant(s) T0: DOUGLAS C. DISBROW 12 YANKEE DRIVE MOUNT HOLLY SPRINGS,PA 17065 DATE OF NOTICE: SEPTEMBER 4, 2001 ~~~ ~~~~ 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. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 01-4698 Frank Federman, Esquire Attorney for Plaintiff °EDE2^~'A1' AND PT-TE.'~AN Frank Federman, Esquire Identification. No. 12248 One Penn Center Plaza at Subu.rbar. Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 COUNTRYWIDE HOME LOANS, INC. F/K/A COUNTRYWIDE FUNDING CORPORATION Plaintiff vs. DOUGLAS C. DISBROW SUSAN E. DISBROW Defendant TO: SUSAN E. DISBROW 12 YANKEE DRIVE MOUNT HOLLY SPRINGS,PA 17065 DATE OF NOTICE: SEPTEMBER 4, 2001 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO.O1-4698 ~r~ ~V~~ 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. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman,Esquire Attorney for Plaintiff ~- - CASE N0: 2001-04698 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS DISBROW DOUGLAS C ET AL DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon DISBROW DOUGLAS C the DEFENDANT at 12 YANKEE DR at 0017:14 HOURS, on the 13th day of August 2001 MT HOLLY SPRINGS, PA 17065 DISBROW by handing to a true and attested copy of COMPLAINT - MORT FORE NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.55 Affidavit .00 Surcharge 10.00 .00 32.55 Sworn and Subscribed to before me this day of A.D. So Answers: ~' ,~-~~ R. Thomas Kline 08/14/2001 FEDERMAN & PHELAN By: ~_ Deputy Sher ff of Prothonotary ' CASE N0: 2001-04698 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS DISBROW DOUGLAS C ET AL DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SBROW SUSAN E the DEFENDANT at 0017:14 HOURS, on the 13th day of August 2001 at 12 YANKEE DR MT HOLLY SPRINGS, PA 17065 by handing to SUSAN DISBROW a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this day of A.D. Prothonotary So Answers: .vim 2 R. ! as Kline 08/14/2001 FEDERMAN & PHELAN By' ~ ~~%~ , ~/~ Deputy Sheriff FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215)563-7000 COUNTRYWIDE HOME LOANS, INC., F/K/A COUNTRYWIDE FUNDING CORPORATION Plaintiff vs. DOUGLAS C. DISBROW SUSAN E. DISBROW Defendant(s) Attorney for Plaintiff :CUMBERLAND COUNTY Court of Common Pleas CIVIL DIVISION NO. 01-4698 VERIFICATION OF NON-NIILITARY 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 lalowledge 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 DOUGLAS C. DISBROW is over 18 years of age and resides at 12 YANKEE DRIVE, MOUNT HOLLY SPRINGS, PA 17065. (c) that defendant SUSAN E. DISBROW is over 18 years of age, and resides at 12 YANKEE DRIVE, MOUNT HOLLY SPRINGS, PA 17065. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. / ~~ FRANK FEDERMAN Attorney for Plaintiff , (Rule of Civil Procedure No. 236 -Revised) COUNTRYWH)E HOME LOANS, INC., F/K/A COUNTRYWIDE FUNDING CORPORATION Plaintiff vs. CUMBERLAND COUNTY Court of Common Pleas CIVIL DIVISION NO. 01-4698 DOUGLAS C. DISBROW SUSAN E. DISBROW Defendant(s) Notice is given that Judgment in the'above captioned matter has been entered against you on SEPTEMBER / , 2001. `~_y~.,. a ~ ~~ ~Y. EP TY If you have any questions concerning this matter, please contact: FRANK FEDERMAN, ESQUI1tE Attorney for Filing Party One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215)563-7000 **THIS FIItM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RLi CEIVED 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. ** 1 n^~^ v/ ~`' ~ c ~ ~--' C --- ~_ 16/\ ~ l:l ~ Vr; ~C r. ~~ -J 1f ~ ~ C ,_J L' -' c ~ ~::' - ~ m -! °~ G ~~ i PRAECIPE FOR WRIT OF EXECUTION -(MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 COUNTRYWIDE HOME LOANS, INC., F/K/A COUNTRYWIDE FUNDING CORPORATION Plaintiff, v, No. 01-4698 DOUGLAS C. DISBROW SUSAN E. DISBROW Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 9/18/01 to 3/6/02 (per diem -23.21) TOTAL $141,210.81 $ 3,945.70 and Costs $145,156.51 I_~~ FRANK FEDE ,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. w~ o W ~ ~ ~ z z~ ~z ~a o~z O F W O ~ w0 O O x 0 W F ~ ~ ~,O ~ O Oa H~ F~ SGT, -Z. V U a°o ~a ~ Q1 A~ UA dzW d' O~ 0 ~~ Wy wo O~ F ~ ~w Ow~ aW. U P. [i ~~ ~~ 00 ~~ ., ~~ as ~ v~ ~7 ~ zz ~~ wa ~~ ~~ as as 00 xx F H 00 ~~ ~~ A A td 'S' a W W ~ w° ~ ~ o a d ~~ °J b d ~. c_~ _v. - ' _~ - m! ` ~' .::. - y=':- _. .~ ~- ' .. rN• . e+~::,:...~, _.:e„a.a=_ers~fr^ri!'ewkub%rs»5xfr' .4LL that certain tract ofland situate in the 3orough of Mourn Holly Springs. Cumber lard County, Peansvlvsnia, bounded and descrbed in acoordance.with a Plan prepared by Walter N. Heine 190 C1 a[e3, inc., dated Decemher 8, 1939 ant recorded in Plan Book o4, Page 90, ,as follows 13Et;~V1VJ,VG at a point in southern dedicated right-of-way line aF Yankee Drive at come: of Lot ti`o. 41; thence slong Yankee Drive =y a curve to the right having a radius of 136.02 feet and an arc distance of 31.2 feet to a point; :hence along Lot No. 43, South 06 degrees 3b minutes 54 seconds East 136,02 feet to s point; thence slong Lot No. 44 on Plan, South 13 degrees 55 minutes 49 seconds i<ast 34.60 feet to a poine; thence along Lac No. 45 on Plan of liberty Woods, South 70 degrees 27 minutes 31 seconds Wesi 45.00 feet m a poirc dLCnce ale Lrits 40 and 47 en plan, North 19 degrees 32 rn:nutes 29 seeonds'Nos; 171.13 Seer to a pa,~t, t~z? Place ofBEGLtiTIING. CON_T~ING 0.2467 acre snd designated as Lot No. 42 on ?tan ot'Libary Wocds_ DEltVG part of the same premises which 'Nilliam :3. Ncrdstrom, =_seeutor of the estate of Ruth Newburg Moore, a/k/aRuth E. Moore, by his deed dated October 1J, 1992 and recorded n the Office of the Recorder of Deeds for Cumberland County in Dead Book 'Y", Volume 75, Paga 2J 3, granted and conveyed to Liberty Assaciaes, A partaershio, Grantor herein. Vested by Warranty Deed, dated 6/2!95, o yen by Liberty Associates, a Partnership to Douglas C. Disbrow and Susan E Disbrow, his wife and recorded 6/8/95 in Libor Book: 123 Page: 292 BEING LINOWN 9S: 12 YANKF.R DRIVE MODNT HOLLY SPRINGS, PA 17065 6, ~ ~~ !~ ~ i l i t~ C~' ~ ~ ~ - ~; c~ t^ ~a ~ C u`, r- ~~ ~ c ~ ~ ~. ~' ~ ~ _ _ _ £~M~N~fni.. .. _. ~teR~' °tMe:NtwRNIF _.d ~~-v"~ ~'.w-~sai'1~ t ?? )9f~.9~~4~~ . -~.. ~~- ,.~ COUNTRYWIDE HOME LOANS, INC., F/K/A COUNTRYWIDE FUNDING CORPORATION Plaintiff, v. DOUGLAS C. DISBROW SUSAN E. DISBROW Defendant(s). NO.Ol-4698 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. l) COUNTRYWIDE HOME LOANS. INC., F/K/A COUNTRYWIDE FUNDING CORPORATION, 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 ,12 YANKEE DRIVE, MOUNT HOLLY SPRINGS. PA 17065 . 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) DOUGLAS C. DISBROW SUSAN E. DISBROW 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 2. Name and address of Defendant(s) in the judgment: DOUGLAS C. DISBROW 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 SUSAN E. DISBROW 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 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) CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION None. -~ 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) MEMBERS 1sT FEDERAL CREDIT UNION 5000 LOUISE DRIVE MECHANICSBURG, PA 17055 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 maybe 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 maybe affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 13 North Hanover Street Carlisle, PA 17013 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. December 6.2001 ~,/~.- DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff r (-1 i:: C;~ '-' n ~;:~~; --~ ' ._s ; - ~, v; ;:= . t_ ~- `" .Ti y' c` ~1 t..~ ~.. _ .. .... ~S6Flf~5+"Rn.,.e4?.1..:.vw: ~.. 5ia ailklrt K 4 FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 1400 One Penn Center at Suburban Station Philadelphia, PA 19103 (215) 563-7000 COUNTRYWIDE HOME LOANS, INC., F/K/A COUNTRYWIDE FUNDING CORPORATION Plaintiff, v. DOUGLAS C. DISBROW SUSAN E. DISBROW Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVII. DIVISION NO.O1-4698 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: Q 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. -"r'~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff .?~. ~ rq~x~sff+sam~.x~. .r . 4 '+~i€~ e ifi4G~w~1~Wes1'~ COUNTRYWIDE HOME LOANS, INC., FIK/A CUMBERLAND COUNTY COUNTRYWIDE FUNDING CORPORATION Plaintiff, No. 01-4698 v. DOUGLAS C. DISBROW SUSAN E. DISBROW Defendant(s). December 6, 2001 TO: DOUGLAS C. DISBROW SUSAN E. DISBROW 12 YANKEE DRIVE 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 MOUNT HOLLY SPRINGS, PA 17065 * *THIS F/RM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. !F YOU HAVE PREV/OUSLYRECEIVED A DISCHARGE IN BANKRUPTCYAND THIS DEBT WAS NOT REAFF/RMED, THIS /S NOT AND SHOULD NOT BE CONSTRUED TO BE ANATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIENAGAlNST PROPERTY. ** Your house (real estate) at ,12 YANKEE DRIVE, MOUNT HOLLY SPRINGS, PA 17065, is scheduled to be sold at the Sheriffs Sale on MARCH 6, 2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $141,210.81 obtained by COUNTRYWIDE HOME LOANS, INC., F/K/A COUNTRYWIDE FUNDING CORPORATION (the mortgagee) against you. If the Sheriff's sale is postponed, the property will be relisted for the JUNE 5, 2002 Sheriff's Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You maybe able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (2151563-7000. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You maybe entitled to a shaze 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 t^a: 9eras. tree; of;and si^,:a;e in ;he 3orough of Vfcu^; Hoi'.y Spr.ags, Cur„bc:larc 'County, Pones;+Ivsnia, bounded a:.d descr'o ed ~~ acco rdarce. wits a ?!an prepared by Walter N. Heinz ?sso ciut e~, Cnc.. dated Decemhar 3, 1989 and racer led in Plan Bock 5~, Page 9Q .as follo•N: 13FGI,v:v1:~/. at a point in southern dedicated rigr.•-a f--way line of Yankee Drve a[ co cncr of i_ot No. 41; ;hence along Yankee Drive by a curve to tl:e right having a relics of 130.03 fe c: and an arc distance of 3 LZ Feet to a paint; :hence along Lot No. 43, South 06 degrees 3E minutes 54 seconds cast 136.03 Fect :o a ?Dint; ;hence along Lot Vo. 44 on P:an, Sou::: 17 degrees 55 minutes c9 serands East 44.50 feet to a poi: t; thence alcng Lot loo. 4_< an Platt of libert•~ W nods, Seutlt 70 degrees 27 minutes 3' seconds 'Ncs: 45,00 feet m a point; dicnce ale'~'o L3ts 4C and 4; cr. P:aa, Verh 19 degrees 72 tr.:u:es 39 seccads Wes; 17:.li fzet ;o a ?tx,~t, tea' Place of BEGLY~7.`i C. CON': tlitiLVG 0._x67 acre and desigaate~ as Loc tio. 43 cr. ?lea o[ Libo.^.y 4VOCd~. I3ENG ?a.^. of the same nrernises which William ?i. Ncrdstrom, E:cecutor ot° the ~ststi; of Ruth ~I~rbur3 Vloere, a/k,'a Ruth c. Vloofe, by `tis deed dated Oc:aber 13, 1953 and rzcord ed :n the Ol~ce of :he Retarder ui T]eeds for Cumberland Ceurty in Deed 3eok ' Y", 'v alums JF, ?age .33, 3ranced and conveyed m Liber^,I ,4ssociates, A?artaer shi p, Granter :aerein. Vested by Warranty Deed, dated 61:/95, ; von by Liberty Associates, a Partnership [o Douglas C. Disbrow and Susan Disbrow, his wife and recorded 6/8/95 in Libe: Book: 123 ?age: 292 BEING I~TOWN AS: 12 YANKEE DRIVE MOIINT HOLLY SPRINGS, PA 17065 ~~ t AFFIDAVIT OF SERVICE PLAINTIFF COUNTRYWIDE HOME LOANS, INC., F/K/A COUNTRYWIDE FUNDING CORPORATION CUMBERLAND COLITITY No. 01-4698 ACCT. #7207317 DEFENDANT(S) DOUGLAS C. DISBROW SUSAN E. DISBROW SERVE DOUGLAS C. DISBROW AT 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 SERVED Served and made known to 1/bvgl3S C~ ~i5~j~((aw,Defendant,on at i ~ ,o'clock~.m., at ~ a k~@ of Pennsylvania, in the manner described below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is W i ~_ ~ ~ ~~ ~ Aduit in charge of Defendant(s)'s residence who refused to give name or relationship. ''^^ Manager/Clerk of place of lodging in which Defendant(s) reside(s). 1--~ } 5 ~~~ ~ 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 ^~ I, `-1J'KQWc~ a tme and correct copy of th the address indicated above, .v ~r~ Height ,7 ~ Weight ~ Race ~G Sex ~ Other~G~Qai C Commomvealth b~~d ~a4 r~ ~~, a competent adult, being duly sworn according to law, depose and state that I personally handed >tice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at ANNE 6. BORYAN, No~Pu6No Sworn to and subscri~d ~Illblf8blllg ilofo, k befo a me t s ~ day ~~1'111~011~1'BS 1 of ew~~+•t, 200 Notary: yiv.. (y..Qm't~G-+-- By: c(..Gr~ PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES &uPIMES OF SERVICE ATTEbIPED. NOT SERVED On the day of , 200_, a[ o'clock - m., Defendant NOT FOUND because: Moved Unlrnown Other: Sworn to and subscribed before me this day of , 200 _. Notary: No Answer Vacant By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215)563-7000 Type of Action - Notice of Sheriff s Sale Sale Date: MARCH 6, 2002 day of ~ e , 200, ,,,~, _. ;-; ~. t"• - _ ,,..= G _~ ,~ ;_; _ - -~ ~ _ :~ :,, --. <_:`;::: t~ ;~ :;~. _. ~, ~mm~eeu.. .. _ 1~4#%~m~~+a ~ ~w ,~3r~; n ~~rss ~ ~ ~~,~ i$P~~2ika AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PLAINTIFF COUNTRYWIDE HOME LOANS, [NC, F/K/A COUNTRYWIDE FUNDING ~ CORPORATION DEFENDANT(S) DOUGLAS C. DISBROW SUSAN E. DISBROW SERVE SUSAN E. DISBROW AT 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 No. 01-4698 ACCT. #7207317 Type of Action - Notice of Sheriff s Sale Sale Date: MARCH 6, 2002 SERVED Served and made known to -/~`' ~ ~ ~ /~ ` ~~ S'~k1J~oU-% , D~eJfendanrt, on the ~~~ day of Y ' C , 200 at i ~`a ,o'clock~.m, at ~~. Y~i/1~ ~ , ®~1OIt1~" ~6~~r ~jf~lZi h-b,S , Commomvealth of Pennsylvania, in the manner described below: _~Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging 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: i N w~ I Description: Age Height 3'la Weight Race ~~ Sex Other ~1<-d- ~'Ot.s~ Vrai ('~ I, Cld1<e i~-'t ~, , C~K'Fy TK , 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 Sheriff s Sale in the mamier as set forth herein, issued in the captioned case on the date and at the address indicated above. NOTARIAL $EAL Sworn to and subscri~d ANNE G. BORYs,N, NO PtIbIN Chambttrsburg 9cro, In befo me is ~ day My Commission Expl of~. ,zoo j. Notary:./) ~~, ~,oi,.,,.,_ By: PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPED. On the day of Moved _ Unlrnown Other: Sworn to and subscribed before me this day of , 200 _. Notary NOT SERVED 200_, at o'clock _.m., Defendant NOT FOUND because: No Answer Vacant By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COUNTRYWIDE HOME LOANS, INC., F/K/A COUNTRYWIDE FUNDING CORPORATION 7105 CORPORATE DRIVE No.: 01-4698 PLANO, TX 72024-3632 vs. DOUGLAS C. DISBROW SUSAN E. DISBROW 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY Kindly mark the judgment that`was entered in the above captioned matter on SEPTEMBER 19.2001 vacated upon payment of your costs only. Fr Federman, Es wire Atto ey for Plaintiff January 7, 2002 ~ ~ ~ ~ a ~~ .; ~~_: ~- .~/ 9 ~ _. ._ ?f R' .. _~ _, e~wMwa+c~,wc~we~aw+a±,w~ec~a~+mst~nnsmrtaa-.=~uz, ti ^sg•• ~~~nai w~.gsi+lv?'~a _ ~~~a~Y{'Ai _ _ -. "pv-; COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ~ SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Federal Natl MtQ Assoc is the grantee the same having been sold to said grantee on the 1 lth day of June A.D., 2003, under and by virtue of a writ Execution issued on the 4th day of March, A.D., 2003, out of the Court of Common Pleas of said County as of Civil Term, 2001 Number 4698, at the suit of Countrywide Home Loans Inc against Douglas c Disbrow & Susan E is duly recorded in Sheriff s Deed Book No. 257, Page 4742. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ~ day of A.D. 2003 Countrywide Home Loans, Inc. f/k/a Countrywide Funding Corporation VS Douglas C. Disbrow and Susan E. Disbrow In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-4698 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he served the within Real Estate Writ, Notice and Description upon the within named defendant, Douglas C. Disbrow, in the following manner: The Sheriff mailed a copy of the pendency of the action by certified mail, return receipt requested, restricted delivery, deliver to addressee only, to the last know address of the defendant, 606 Waight St., Beaufort, SC 29902. This letter was mailed under the date of Apri17, 2003. Return receipt cazd was signed by defendant, Douglas Disbrow on an April 10, 2003 and returned to the Cumberland County Sheriff s Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he served the within Real Estate Writ, Notice and Description upon the within named defendant, Susan E. Disbrow, in the following manner: The Sheriff mailed a copy of the pendency of the action by certified mail, return receipt requested, restricted delivery, deliver to addressee only, to the last know address of the defendant, 606 Waight St., Beaufort, SC 29902. This letter was mailed under the date of April 7, 2003. Return receipt card was signed by defendant, Susan Disbrow on an April 10, 2003 and returned to the Cumberland County Sheriffs Office. Brian Bazrick, Deputy Sheriff, who being duly sworn according to law, states that on Apri108, 2003 at 12:27 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster.and Description, in the above entitled action, upon the property of Douglas C. Disbrow and Susan E. Disbrow located at 12 Yankee Drive, Mt. Holly Springs, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants, to wit: Susan E. Disbrow, by regulaz mail to her last known address of 606 Waight Street, Beaufort, SC 29902. This letter was mailed under the date of April 16, 2003 and never returned to the Sheriff s Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants, to wit: Douglas C. Disbrow, by regular mail to his last known address of 606 Waight Street, Beaufort, SC 29902. This letter was mailed under the date of April 16, 2003 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on June 11, 2003 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Frank Federman for Federal National Mortgage Association. It being the highest bid and best price received for the same, Federal National Mortgage Association of 1900 Market Street, Suite 800, Philadelphia, PA 19103, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $757.13. Sheriffs Costs Docketing $30.00 Poundage 14.85 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 8.28 Certified Mail 15.84 Levy 15.00 Surcharge 30.00 Law Journal 265.40 Patriot News 216.52 Share of Bills 25.24 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $ 757.13 Sworn an~ subscribed to before me S~ swe ;,r~~ This ~ day of ~Q~~'~ '~''a"'"'~~ R. Thomas Kline, Sheriff 2003, A.D. cc ++ 11 ^!' P othonotary BY J ~Y~J.1~ ~! ~ Real Estate Deputy ~~ ~ ~. ~ ~~~ c~ ti i aa6 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO O1-4698 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due COUNTRYWIDE HOME LOANS, INC. f/k/ a COUNRYWIDE FUNDING CORPORATION Plaintiff (s) From DOUGLAS C. and SUSAN E. DISBROW, 12 YANKEE DRIVE, MOUNT HOLLY SPRINGS PA 17065. (1) You aze duetted to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 12 YANKEE DRIVE, MOUNT HOLLY SPRINGS PA 17054 (SEE ATTACHED LEGAL DESCRII'TION) . (2) You aze also duetted 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 aze duetted to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $157,543.21 L.L. Interest 3/5/03 TO 6/11/03 @ $25.90 per diem $2,564.10 Atty's Comm % Due Prothy $1.00 Atty Paid $289.65 Other Costs Plaintiff Paid Date: MARCH 4, 2003 CURTIS R. LONG Proth tary - (Seal) By: Cep ~ Depu REQUESTING PARTY: Name FRANK FEDERMAN ESQUIItE Address: 1617 JFK BLVD, SUITE 1400 ONE PENN CENTER @ SUBURBAN STATION PHH,ADELPHIA PA 19103-1814 Attorney for: PLAINTIFF Telephone: (215)563-7000 Supreme Court ID No.12248 ;~~,.~ 4» Real Estate Sale # 64 On March 14, 2003 the sheriff levied upon the defendant's interest in the real property situated in Mt. Holly Springs Borough, Cumberland County, PA known and numbered as 12 Yankee Drive, Mt. Holly Springs, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 14, 2003 By:JO~,sy~ Real Estate Deputy ~~ ~~ ~A~ C9/,~ ~~n- ., ~. _m ~ .rr~ s~~~~~ COUNTRYWIDE ROME LOANS, INC. F/K/A COUNTRYWIDE FUNDING CORPORATION Plaintiff, v. DOUGLAS C. DISBROW SUSAN E. DISBROW Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO.Ol-4698 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) COUNTRYWIDE HOME LOANS. INC. F/K/A COUNTRYWIDE FUNDING CORPORATION, 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 .12 YANKEE DRIVE. MOUNT HOLLY SPRINGS. PA 17065 . 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) DOUGLAS C. DISBROW SUSAN E. DISBROW 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 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 is a record lien on the real property to be sold; Name Last Known Address (if address cannot be reasonably ascertained, please indicate) :~, ~, None ,: ~ ~`~~ •~ lYy A ~,~ 4 ~~ ~~ 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) MEMBER 1sT FEDERAL CREDIT UNION 5000 LOUISE DRIVE MECHANICSBURG, PA 17055 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 maybe 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 Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 13 North Hanover Street Carlisle, PA 17013 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 unswom falsification to authorities. 1 February 27, 2003 ~. ~ p ~ ~ DATE RANK FE ERMAN, ESQUIRE ttomey for lainfiff COUNTRYWIDE HOME LOANS, INC. F/K/A COUNTRYWIDE FUNDING CORPORATION Plaintiff, v. DOUGLAS C. DISBROW SUSAN E. DISBROW Defendant(s). CUMBERLAND COUNTY No. 01-4698 February 27, 2003 TO: DOUGLAS C. DISBROW 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 SUSAN E. DISBROW 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 * *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTA/NED WILD BE USED FOR THAT PURPOSE. !F YOU HAVE PREVIOUSLY RECEIVED A D/SCHARGE IN BANKR UPTCYAND 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 ,12 YANKEE DRIVE, MOUNT HOLLY SPRINGS. PA 17065, is scheduled to be sold at the Sheriffs Sale on 6/11/03 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $157,543.21 obtained by COUNTRYWH)E HOME LOANS. INC. F/K/A COUNTRYWIDE FUNDING CORPORATION (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 MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You maybe able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) 1. If the Sheriffs Sale is not stopped, your property. will be sold to the highest bidder. You may find out the price bid by calling (215 563-7000. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You maybe entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) aze filed with the Sheriff within ten {10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800)990-9108 ALL that certain tract of land situate in the Borough of Vtount Holly Springs. Cumberland County, Pennsylvania, bounded and descrbed s aeeardanee with a Plan prepared by Wal:er N. Heine A.aaociates, Inc., dated December 8, 1989 and retarded s Plan Hook 64, Page 90, as follows: DEGINNLVG u a point in southern dediested right-aF--way line of Yankee Drive at come: aF Lot No. 41; [henea along Yankae Drive by a eurva to the right leaving a radius cf I3ti.0: feet and an arc diswnce of 811 feet to a paint; :hence along Lo[ No. 43, South 06 degrees 36 minutes 34 seconds East 136.02 Peet [o a point; thence along Lot No. 44 on Plan, South 13 degrees 55 minutes 49 xwnds Fast 44.60 Feet to a point; eheace along Lat No. 43 an Plan of Liberty Woad; South 70 degrees 27 minutes 31 seconds Wesi 13.00 Feet to a point; [hence slol~$ Ldta 40 and 41 on Plan, North t9 degrees 32 minutes 29 seconds Weat 171.13 feet to a pajl;t, t~fe' Place ofHEGLYNNG. CONTAINING 0.2467 sue and dnignated as Loc :Ia. i2 on Plan ofLibec:y Woa.:a BEING KNOWN AS 12 YANKEE DRIVE, MOUNT HOLLY SPRINGS, PA 17065. TAX PARCEL # 23-35-2316-094 TITLE TO SAID PREMISES IS VESTED BY WARRANTY DEED IN DOUGLAS C. DISBROW AND SUSAN E. DISBROW, HIS WIFE BY DEED FROM LIBERTY ASSOCIATES, A PARTNERSHIP, DATED 6/2!1995 RECORDED 6/1995, IN DEED BOOK VOLUME 123 PAGE 292. ,~.~,-~. THE PATRIOT NEWS THE SUNDAY. PATRIOT NEWS Proof of Publication UnderAd No. 567, 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 Asst. 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 The Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 22nd and 29th day(s) of April and the 6th day(s) of May 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 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 in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION ................................ .. ....../.~-.. `~~_ COPY Sworn to and subscrib d afore me 14th day of ay .[ SALE #64 Notarial Seal Terry L. Russell, Notary Public CiryOfHarrisburg,DauphinCounty NOTARY PUBLIC ' My Commission Expires June 6, 2006 Member, Pennsylvania Association Of Notaries My commission expires June 6, 2006 ' ~ 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 $ 214.77 Probating same Notary Fee(s) $ 1.75 Total $ 216.52 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 .................................................................... 's, Ge-, dated December 8, 1989 n P1~Book 64, Page 90, as at-i`point in southern dedicated' oCYavkee Drive at comer of Lot ilobgYadkee Drive by a curve in atadius of 136.02 feet and ao are `fee[ to aaoin[; tlrenca.alone Lot 55 s. ~ '.. Drive, Moutit dated- fiYli ok Yalusrie PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. 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: APRIL 25, MAY 2, 9, 2003 Affiant fiuther 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. s~ ~- rs Marie Coyne, 'tor SWORN TO AND SUBSCRIBED before me this 9 day of MAY, 2003 LOlS E. SidYG~~,h°ctary Pu011c Cadisie 6arva, Cu~n~Gdand County My Cc;:::ncn Expires March 5, 2505 ,r_. REAL ESTATE SALE NO. 64 Writ No. 2001-4698 Civil Countrywide Home Loans. Inc., f/k/a Countrywide Funding Corporation vs. Douglas C. Disbrow and Susan E. Disbrow Atty.: Frank Federman ALL that certain tract of land situ- ate in the Borough of Mount Holly Springs, Cumberland County, Penn- sylvania bounded and described in accordance with a Plan prepared by Walter N. Heine Associates, Inc., dated December 8, 1989 and re- corded in Plan Book 64. Page 90, as follows: BEGINNING at a point in south- ern dedicated right-of-way line of Yankee Drive at comer of Lot No. 41; thence along Yankee Drive by a curve to the right having a radius of 136.02 feet and an arc distance of 81.2 feet to a point: thence along Lot No. 43, South 06 degrees 36 minutes 54 seconds East 136.02 feet to a point; thence along Lot No. 44 on Plan, South 13 degrees 55 minutes 49 seconds East 44.60 feet to a point; thence along Lot No. 45 oh Plan of Liberty Woods, South 70 degrees 27 minutes 31 seconds West 45.00 feet to a point; thence along Loffi 40 and 41 on Plan, North 19 degrees 32 minutes 29 seconds West 171.13 feet to a point, the Place of BEGINNING. ~CONTA(NING 0.24fi7 acre and designated as Lot No. 42 on Plan of Liberty Woads. BEING KNOWN AS 12 YANKEE DRIVE, MOUNT HOLLY SPRINGS, PA 17065. TAX PARCEL #23-35-2316-094. TITLE TO SAID PREMISES IS VESTED by WarranTy Deed in Doug- las C. Disbrow and Susan E. Dis- brow, his wife by Deed from Lib- ertyAssociates, aPartnersMp, dated 6/2/2995 recorded 6/2995, in Deed Book Volume 123 Page 292. Countrywide Home Loans, Ina f/k/a In The Court of Common Pleas of Countrywide Funding Corporation Cumberland County, Pennsylvania VS Writ No. 2001-4698 Civil Term Douglas C. Disbrow and Susan E. Disbrow 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 30.00 Surcharge 30.00 Posting Handbills 15.00 Law Library .50 Prothonotary 10 0 Share of Bills 24.20 Mileage 9.10 Levy 15.00 Advertising 15.00 Certified Mail Poundage 2.80 Postpone Sale Law Journal Patriot News $142.60 paid by attorney Sworn and subscribed to before me So Answers: ~` This ~1~1~Cday of ~'~"~'~ ~°'~ dddd ~~~/ R. Thomas Kline, Sheriff 200; A.D.Pc. ~e~,~ ~S BY Prothonotary Real Esta e Deputy ~"Sb n~~,53~ 1 ~~ COUNTRYWIDE HOME LOANS, INC., F/K/A COUNTRYWIDE FUNDING CORPORATION Plaintiff, v. DOUGLAS C. DISBROW SUSAN E. DISBROW Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO.Ol-4698 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) COUNTRYWIDE HOME LOANS INC. F/K/A COUNTRYWIDE FUNDING CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,12 YANKEE DRIVE, MOUNT HOLLY SPRINGS, PA 17065 . 1. Name and address of Owner(s) or reputed Owner(s): Name DOUGLAS C. DIS$ROW SUSAN E. DISBROW Last Known Address (if address cannot be reasonably ascertained, please indicate) 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 2. Name and address of Defendant(s) in the judgment: DOUGLAS C. DIS$ROW 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 SUSAN E. DISBROW 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 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. 4. Name and address of last recorded holder ~f every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) MEMBERS 1sT FEDERAL CREDIT UNION 5000 LOUISE DRIVE MECHANICSBURG, PA 17055 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 maybe 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 maybe affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and con•ect to the best of my personal knowledge or information and belief. I understand that false statements herein aze made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. December 6.2001 w~ DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ,COUNTRYWIDE HOME LOANS, INC., F/K/A COUNTRYWIDE FUNDING CORPORATION Plaintiff, v. DOUGLAS C. DISBROW SUSAN E. DISBROW Defendant(s). CUMBERLAND COUNTY No. 01-4698 December 6, 2001 TO: DOUGLAS C. DISBROW 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 SUSAN E. DISBROW 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 * *THIS FIRM /S A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED W/LL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIO USLY RECEIVED A DISCHARGE IN BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS /S 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 ,12 YANKEE DRIVE, MOUNT HOLLY SPRINGS, PA 17065, is scheduled to be sold at the Sheriffs Sale on MARCH 6, 2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $141,210.81 obtained by COUNTRYWIDE HOME LOANS, INC., F/K/A COUNTRYWIDE FUNDING CORPORATION (the mortgagee) against you. If the Sheriff's sale is postponed, the property will be relisted for the JUNE 5, 2002 Sheriff s Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You maybe able to stop the sale by filing a petition asking the Court to strike or open the judgment, ifthe judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You maybe entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717)249-3166 (800)990-9108 .~l-L ::ac =ertai~ :rat; o';and si:3a;e in .he 3oroush of Vfoua; 'r_cl!; Spr..^.gs, Cum6cr;ard ~:ounty, Penr.3ylvati a, bcunded and des[: 'oed i~ acardarce, with a ?'.aa prepared Sy Wai:er N, Hei re .lsse cites, inc., dated December 8, 1589 ant recorded in Plan Hock 5-, Page SC, .as fo Mows: I3SCI~~ivLVG ac a point in souther., dedicated :igr.:-af--way fine oFYankee Drive at cocnc: or Lot Mo. 41; thence along Yanicea Drive by a curve to the :-fight having a radios of 13ti,02 feet and an arc distance of 31.~ feat to a paint; ;hence along Lat ~ io, 43, Soeth 06 degrees 36 minutes 54 seconds cast ]36.C: feet :n a poinr. ;hence along L of *Io. 44 on P:ar., South 13 degrees 9~ minute 49 seconds East 44,60 set to a poi, t; [hence aleng Loe No. 49 on 2lan of Libenv Woods, Seuth "70 degrees 27 minutes 31 seconds 'Nest 49,00 feet :0 3 rain[; :hence a!c'~ Lets 40 and 4: en P:an, Nerz:: 19 dey ees 32 m~^,u:es S9 seconds W'es: 17 i. l3 test to a po}at, tie - Plata of HEGL`w~~t`iC. - CO~V?:4I,VZVG 0,.46; acre and dcsignateci as Lo[ ~"o. 42 or.?last oF_ibory Wocd~. I3ENG?a.^, of the same premises which `Xilliam $.:icrdst:om, 5secutnr of :he Es2sce ui Ruth Newourg Moore, a/ic'a Ruth c. Vioore, by !tis deed dated October 17, 1552 and : ecerd ed in the 01$ce of tae Recorder ei Deeds far Cumberiard Ccurty in Dccd 3eok 'Y", 'v'oiuma J3, Page .33, 3ranted aAd conveyed to Liberty.~ssaciaces, A Par*nership, Granter he: sin. Vested by Warranty Deed, dated 612/95, givea by Liberty Associates, a PartnershiQ to Dou~as C. Disbrow and Susan _ Disbrow, his wife and recorded 6/8/95 in Liber Book: 123 Page: 292 BEING KNOWN AS: 12 YANKEE DRIVE MOUNT HaLLY SPRINGS, PA 17065 ~" WRIT OF EXECUTION anti/ot ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 01-4698 CIVIL ~ TES CIVIL ACTION -LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Countrywide Herne Loans, Inc. , F/K/A Countrywide Funding Corporation PLAINTIFF(S) from Douglas C. Disbrow and Susan E. Disbrow, 12 Yankee Drive, Mount Holly Springs, PA 17065 (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 as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) islare 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 propertyofthedefendanl(s)notlevieduponansubjecttoattachmentisioundinthepo@sessionofanyoneother than a namedgamishee, you are directedto rrotHy hirtVherthat he/she has been added as agarnishee and is ehjoiried as above stated. Amount Due $141,210.81 fran 9/18/01 to 3/6/02 (per diem - Interest 23 2}}--$3-$45 70 arv~CASts Atty's Comm Atty Paid $~n. ss Plaintiff Paid L.L. $.50 Due Prothy Other Costs Date: nAC-amt,er_10. 2001 REQUESTING PARTY: Curtis R. Long Prothonotary, C~ivfif~Division Deputy Name Frank Federman Esa. Address: One Penn Center at Suburban Station Suite 1400 Philadelphia PA 19103-1814 Attorney tor: P1 a; nt; ff Telephone: 7 t 5-5Fi"2-7000 Supreme Court ID No. REAL ESTATE ~~ ~~. ~+~ On December 12, 2001, the sheriff levied upon the defendant's interest in the real property situated in Borough of Mt. Holly Springs, Cumberland County, PA, known and numbered as 12 Yankee Drive, Mount Holly Springs, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: December 12, 2001 By: ~6 ~v14.i~1 Real Estate Deputy c~ a ~~~r\}~~~3 ti~1 ~ > ~\ ~~ati~ ~ . ~~`~°,3'~~ 1.~"~`N`' '~ L ~~~ FEDERMAN ANb PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (2151 563-7000 COUNTRYWIDE HOME LOANS, INC. F/K/A COUNTRYWIDE FUNDING CORPORATION 7105 CORPORATE DRIVE PLANO, TX 75024-3632 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION v. Plaintiff, NO. 01-4698 DOUGLAS C. DISBROW SUSAN E. DIS$ROW 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 DOUGLAS C. DISBROW and SUSAN E. DISBROW, 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 Plaintiff s damages as follows: As set forth in Complaint Interest from 7/2/01 to 3/4/03 TOTAL $138,785.51 $ 18,757.70 $157,543.21 I hereby certify that (1) 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. I FRANK EDERMAN, ESQ IRE Attorney for Plaintiff DAMAGES A~iRE HEREBY ASSESSED AS INDICATED. ~ DATE: ~J - ~ ~~~ ~U.'l~vL~t-(/J PRO PROTHY c,- ~_~, c ~ ' r , F T ~.,~, ~n c>>'r ~ n-i -~.~ s v. r i~; _~_ , ,~i -~;. -i aaxanre4+mN~w,nrera~.w~a~~s ... ss~m~m~+e~e!muett's a* ,~ vsr,. ,. _, ~r ,: ~ . ~-, ~i.~ ;,moo, s re.s~~in+at ~, ~, ~ ~,mu,~,a . _. 1~'EDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevazd Suite 1400 Philadelphia, PA 19103-1814 (~ ~ s) SF~_7nno COUNTRYWIDE HOME LOANS, INC. F/K/A COUNTRYWIDE FUNDING CORPORATION Plaintiff vs. DOUGLAS C. DISBROW SUSAN E. DISBROW Defendant(s) TO: DOUGLAS C. DISBROW 12 YANKEE DRIVE. MOUNT HOLLY SPRINGS, PA 17065 DATE OF NOTICE: FEBRUARU 21. 2003 ~0~~ ~~~~ 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. IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 01-4698 CIVIL TERM rank Federman, Esquire Attorney for Plaintiff „~ FEDERMAN AND PHELAN BY: FRANKFEDERMAN,ESQUII2E Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 PhiIadeIphia, PA 19103-1814 (~~ ~5~~_7nnn COUNTRYWIDE HOME LOANS, INC. F/K/A COUNTRYWIDE FUNDING CORPORATION Plaintiff vs. DOUGLAS C. DISBROW SUSAN E. DISBROW Defendant(s) TO: SUSAN E. DISBROW 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 DATE OF NOTICE: FEBRUARU 21, 2003 Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 01-4698 CIVIL TERM 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. IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 Frank Federman, Esquire Attorney for Plaintiff FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOIIN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215)563-7000 COUNTRYWIDE HOME LOANS, INC. F/K/A COUNTRYWHE FUNDING CORPORATION 7105 CORPORATE DRIVE ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION v. Plaintiff, DOUGLAS C. DISBROW SUSAN E. DISBROW Defendant(s). NO.O1-4698 VERIFICATION OFNON-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 DOUGLAS C. DISBROW is over 18 years of age and resides at , 12 YANKEE DRIVE, MOUNT HOLLY SPRINGS, PA 17065 . (c) that defendant SUSAN E. DISBROW is over 18 years of age, and resides at ,12 YANKEE DRIVE, MOUNT HOLLY SPRINGS, PA 17065. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. i1 nM ~,A1~ RANK FE ERMAN, ESQUIRE Attorney for laintiff ~- F ~~ ~ ,~ ~u ~' ~ cr ",1 N ~' _ w V 1 h 1 "~~ ~~ ~~ ~rn V ` C1 d r., ~- ~,., _., .~;;- <<> i i_- ~~ ~- A ~_- K- ~~ ~. .~ M~' ~..7 a~ (P r~ -, ~; ~'< -u, fl~eS~N-!dWy~M~R^.. _ _ ~~~X^d~wvetpas~vwamm. ~ra-se^~=++&ros~-.3T v _s - i .. vy~ -~. s.7~j-ice tv.xUlAn+wkk9~~1'i r FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215)563-7000 COUNTRYWIDE HOME LOANS, INC. F/K/A COUNTRYWIDE FUNDING CORPORATION v. Plaintiff, DOUGLAS C. DISBROW SUSAN E. DISBROW Defendant(s). NO. 01-4698 CERTIFICATION FRANK FEDERMAN, ESQiJIItE, 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: Q an FHA mortgage () non-owner occupied O vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. RANK F ~DERMAN, ESQiJIRE ttorney fo Plaintiff ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVII~ DIVISION K~ . f1 E-°` = r ..mss 'Ta-' :~:? ~- -- ~:*z ,. cr,. °, ` K :: ,-. _~> i ` cam) ~: ~.J ~7 t3"+ -_. L.x. _, .. _ _ ~mmaks~m. _ _.. _. ~af+'i~ce':~^~,~. ePr=~. ~.n.NFx ,~a~k?p We'~~sit~gG'='~ , ~, COUNTRYWIDE HOME LOAN5, INC. F/K/A CUMBERLAND COUNTY COUNTRYWIDE FUNDING CORPORATION Plaintiff, No. 01-4698 v. DOUGLAS C. DI5BROW SUSAN E. DISBROW Defendant(s). February 27, 2003 TO: DOUGLAS C. DISBROW SUSAN E. DISBROW 12 YANKEE DRIVE 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 MOUNT HOLLY SPRINGS, PA 17065 * *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOUHAVE PREVIOUSLYRECEIVED ADISCHARGE IN BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLYENFORCEMENT OF A LIENAGAINST PROPERTY. Your house (real estate) at ,12 YANKEE DRIVE, MOUNT HOLLY SPRINGS, PA 17065, is scheduled to be sold at the Sheriffs Sale on 6/11/03 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $157,543.21 obtained by COUNTRYWIDE HOME LOANS. INC. F/K/A COUNTRYWIDE FUNDING CORPORATION (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: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You maybe able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You maybe entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND 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 ,ILL that certain trace of land ai[uate in the Borough of btount Holly Springs. Cumberland County, P¢ntuy!vania, bounded and descrbed s acca rdance with a Plan prepared by WaL•er N. Heine Assoeintea, int., dated December 8, 1989 and recorded s Plan Book fi4, Page 90, as follows: DEGINNINC at a point in southern dedicated right-aF way line of Yanke¢ Drive at come: of Lat No. 41; thence along Yankee Drive by a cuty¢ to the right having a radius of 136.02 feet and an are distance of 8 LZ fee[ to a paint; :henc¢ along Lot No. 43, South 06 degrees 36 minutes Sa secanda Eaat 136.02 feet to a point; thence along Lor No. a4 on Plan, South I7 degreo 55 minutes 49 uwnda East 44.60 feet to a point; thence along Lot No. 45 an Plan of liberty Woods, South 70 degree 27 minutes 3I seconds West 45.00 feet to a point; eltenee alol$ Ldes 40 and al on Plan, North 19 degrees 72 minutes 29 seconds Weat 171.13 feet to a ptg9t, [flit' Plate ofBEGLVMNG. CGNT~INC 0.2467 acre and designated as Loc No. 42 on Plan ofLibery Woo.'.e BEING KNOWN AS 12 YANKEE DRIVE, MOUNT HOLLY SPRINGS, PA 17065. TAX PARCEL # 23-35-2316-094 TTTLE TO SAID PREMISES IS VESTED BY WARRANTY DEED IN DOUGLAS C. DISBROW AND SUSAN E. DISBROW, HIS WIFE BY DEED FROM LIBERTY ASSOCIATES, A PARTNERSHIP, DATED 6/2!1995 RECORDED 6/1995, IN DEED BOOK VOLUME 123 PAGE 292. P J ~. l h7 7`, `.s.. __ ~t _~_ Y ~ _l .,, C C+J " `l '."j~ ~~ `+f -:7 Z 9pe3eRiWHS§9R~`a s~sa _A~ _ _PaNl~xwgu~ SSNt I'A 9in. ~~R K9 a^*VFAir~f Yrs.1-i COUNTRYWIDE HOME LOANS, INC. F/K/A ,COUNTRYWIDE FUNDING CORPORATION Plaintiff, v. DOUGLAS C. DISBROW SUSAN E. DISBROW Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVII. DIVISION NO.Ol-4698 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. l) COUNTRYWIDE HOME LOANS, INC. F/K/A COUNTRYWIDE FUNDING CORPORATION, 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 ,12 YANKEE DRIVE, MOUNT HOLLY SPRINGS, PA 17065 . 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate} DOUGLAS C. DISBROW SUSAN E. DISBROW 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last lrnown 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 ,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) MEMBER 1sT FEDERAL CREDIT UNION 5000 LOUISE DRIVE MECHANICSBURG, PA 17055 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 maybe 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 maybe affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 12 YANKEE DRIVE MOUNT HOLLY SPRINGS, PA 17065 13 North Hanover Street Carlisle, PA 17013 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. February 27, 2003 DATE RANK FE ERMAN, ESQUIRE ttorney for laintiff ~n~r C ~ ~~ _ ~' a ^31:T- ~ J ~ .- __- t _ c: .,., r ~- C' .,r, T c. ~' -- Yar~=asaaae,7 .. Rt4':'z~'s ~ ~ :. ~,T-, ,,n .yr~:,, 6M a~ya:p~ `~4~1[`:~rugaei PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R,C.P.3180-3183 COUNTRYWIDE HOME LOANS, INC. F!K/A COUNTRYWIDE FUNDING CORPORATION Plaintiff, v. No. 01-4698 DOUGLAS C. DISBROW SUSAN E. DISBROW Defendant(s). TO THE DIItECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $157,543.21 Interest from 3/5/03 to 6/11/03 $ 2,564.10 and Costs (per diem -$25.90) TOTAL $160,107.31 ~ FE RMAN, 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. ~: R~ ~_ w~ oz w~ ~z a~ zz ~Q ~z ow o~z ~ W o ~ ° A o z 0 ~ 0 0 '~o o~ ~o~ xw F~ ~~ pw Mp U U as ~~ A ~~'„ ~A ~w o~ A z 0 U ~~ w~ u o° F ~ ~w° 3 °' x~ 00 a~ U w ~~ ~~ 00 r n ,~ .., d' ~ 0.i W v~ ~ C7 C7 zz ~~a as ~~ ~~ as as 00 xx ~~ ~~ ~~ ~~ N N ti ti ~: b C~ c: `~ L7 n;s,- -; ~c~' U; .C ( I ='' G _~ c~~ c_.~ _:~, ar ~~~ rv- :s9 ~] (}"5 ,sy %, _, .--. ~ ,. w'q ~~'. ~, ALL chat certain tract of land situate in the Horough of Mount Holly Springs. Cumberland Ctunty, Pennsylvania, bounded and descrbed in accordance with a Plan prepared by Wal:er N. Heine Associates, inc., dated December 8, 1989 and retarded in Plan Book 64, Page 90, as follows: BEGINNING at a point in southern dedicated right-af--way line of Yankee Driva a[ come: of Lot No. 41; thence along Yankee Drive by a curve to elte right Itavirtg a radius tE I36.02 Feec and an are distance oP812 feet to a point; thenca along Lot No. a3, South O6 degrees 36 minutes 34 xconda Eaac 336.02 Feet to a point; thence along Lot No. 44 on Plan, South 17 degrees SS minutra 49 xranda East 4x.60 Feet to a point; thence along Lot No. 45 on Plan of liberty Wood; South 70 degren 27 minutes 31 seconds West 13.00 feet eo a point; thence alal+,~ Ldta 40 and 41 on Plan, North t9 degrees 32 minutes 29 seconds West 171.13 feee [o a po}at, tie P[aee ofBEGLYNiNG. CONTAIiVING 0.2467 aero and dnignated ae Lot No. 42 on ?tan ofLibeay Woo.:e BEING KNOWN AS 12 YANKEE DRIVE, MOUNT HOLLY SPRINGS, PA 17065. TAX PARCEL # 23-35-2316-094 TITLE TO SAID PREMISES IS VESTED BY WARRANTY DEED IN DOUGLAS C. DISBROW AND SUSAN E. DISBROW, HIS WIFE BY DEED FROM LIBERTY ASSOCIATES, A PARTNERSHII', DATED 6/2!1995 RECORDED 6/1995, IN DEED BOOK VOLUME 123 PAGE 292. .,. ~-., ~'; r~.~) 00 ~ ~ cr '~~ , \ ~~~ U ~ ("} rm7 r~ ~ J ~ - _. ,I._ ;~ i~' r _- =t _:~` ~s cr x%~PEeac~*a R ~?2a ~"_rv . ._,~ s~v~~kFi'~^ia~ra~wF+~~!'1YI~ -s WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-4698 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due COUNTRYWIDE HOME LOANS, INC. f/k/ a COUNRYWIDE FUNDING CORPORATION Plaintiff (s) From DOUGLAS C. and SUSAN E. DISBROW, 12 YANKEE DRIVE, MOUNT HOLLY SPRINGS PA 17065. (1) You aze duetted to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 12 YANKEE DRIVE, MOUNT HOLLY SPRINGS PA 17054 (SEE ATTACHED LEGAL DESCRIPTION) . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an 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 aze duetted to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $157,543.2 L.L. Interest 3/5/03 TO 6/11/03 @ $25.90 per diem $2,564.10 Atty's Comm % Due Prothy $1.00 Atty Paid $289.65 Other Costs Plaintiff Paid Date: MARCH 4, 2003 CURTIS R. LONG Prothon ry (Seal) By: IR.t~,Q„ Depu REQUESTING PARTY: Name FRANK FEDERMAN ESQUIItE Address: 1617 JFK BLVD, SUITE 1400 ONE PENN CENTER @ SUBURBAN STATION PHILADELPHIA PA 19103-1814 Attorney for: PLAINTIFF Telephone: (215)563-7000 Supreme Court ID No. 12248 ~,,, e iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RE: COUNTRYWIDE HOME LOANS, INC. F/WA COUNTRYWIDE FUNDING CORPORATION ) CIVIL ACTION vs. DOUGLAS C. DISBROW ) CIVIL DIVISION SUSAN E. BISBROW ) NO. 01-4698 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS: I, FRANK FEDERMAN, ESQUIRE attorney for COUNTRYWIDE HOME LOANS, INC. F/KIA COUNTRYWIDE FUNDING CORPORATION hereby verify that on 3!4/03 & 4/22/03 true and correct copies of the Notice of Sheriff's sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. 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N a c • ^ ~ w ro s n [ ~ O M ~ k y 0 ~ O ^,~~, ro ryn ~m~ ~a~z ~ Y Q O s ro r 'y\ Al Y< W„ i y y `.}~1 yy ~d t" ' ~' p w O ~ ~ r~0 ~. ., B H ~ b ~ ~ m ~ C7 D a < p' ti F R ~ ro Ir ~ H ro y ~ W a ~ 11 W A ~ w ., "s ~ a ro ~' !° - ~ w N O n A < . y ao .'--?' LN~`' b __ .~ ~ ~~_., ,~~ ZP °s?.y ~ F ti ( w +~ .. _. - i .: w~wev sours 02 ,A $ 01 80° . 0004300377 RPR 22 2003 - MAILED FRO M ZiP CODE 1 3103 -I ''Maw ~a~ o m w ~ m 0. ~t 1 ro O '-1 l~ r~~ ro ~~~ ~ y ,~~ ~~r •• y H °w 1 H ~~ A Vl y l~ a 0